Recital 24*
Commission proposal
| (24) When using online services, individuals may be associated with online identifiers provided by their devices, applications, tools and protocols, such as Internet Protocol addresses or cookie identifiers. This may leave traces which, combined with unique identifiers and other information received by the servers, may be used to create profiles of the individuals and identify them. It follows that identification numbers, location data, online identifiers or other specific factors as such need not necessarily be considered as personal data in all circumstances. |
EDRi’s Proposed amendment
| (24) When using online services, individuals may be associated with one or more online identifiers provided by their devices, applications, tools and protocols, such as Internet Protocol addresses, |
Justification
The Commission proposal significantly reduces the applicability of data protection principles to such online identifiers. It should be noted that the leaked draft for the interservice consultation stated that such online identifiers should always be considered personal data. The proposed amendment makes it clear that such identifiers should be considered personal data, unless they demonstrably are not.
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