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I have a few questions on what consists of PII. I know some are classified as linked and some as linkable, but if a question comes up as “what consists of PII”, would they both be correct?
I have a list that I would like to know if they would be classified as PII or not under CIMA:
1. IP Address
3. Telephone numbers (including old phone numbers?)
4. First pet’s name
5. Mother’s maiden name
6. Husband/Kids name’s
7. Sport affiliation
8. Position in a Company/Charity/Association
9. First car model
10. Old address
I’m not a legal expert, but I think that the principle is that the data must identify an individual.
IP address doesn’t because it just identifies a machine, often temporarily (dynamic).
Current telephone number might (for a mobile registered to a specific user)
Position in a company probably does, if the information is up-to-date.
Old address – probably not as there might be many people who lived there.
For 4,5,6,9 – these are commonly used as security questions when you forget your password. So wanted to understand if they would be classified as PII, as the information on conjunction with other information could identify an individual?
They are not PII. There is no way you can go from a pet called Fido to the person nor a supporter of MUFC to a person. It’s rather like asking someone to enter a 4 digit PIN – many people could have the same, probably 1234!