Nameless data can still be personal

Roland Perry ukcrypto at chiark.greenend.org.uk
Sat, 8 Nov 2008 09:41:04 +0000


In article <1374735793.20081108003538@originalthinktank.org.uk>, Chris 
Salter <ukcrypto@originalthinktank.org.uk> writes

>While I have always been
>careful not to include any 'end user' identifiable information in any
>published web statistics, I've otherwise viewed both logs and reports
>as proprietary (mine) rather than (other individuals) personal data.

They can be both. The collection is "yours" as a data controller, 
comprising other people's personal data (unless the logs have been 
thoroughly anonymised).

>Not that who accesses the sites that I administer would in practice be 
>considered sensitive information.

"Sensitive data* has a jargon meaning (indicating religion etc...) but 
it's a slippery slope to start second-guessing whether or not anyone 
would "care" that the information you have about them was leaked.
-- 
Roland Perry