DEFINITION OF 'PERSONAL DATA'

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Reference: ENQ0237670

31 March 2009

Dear Mr Robinson,

Thank you for your email correspondence dated 5 March 2009, in which you
make an enquiry with regard to the provisions of the Data Protection Act
1998 (the DPA).

In your enquiry you ask whether a ‘reference number and name’ would
constitute personal data for the purposes of the DPA.

I should initially explain that the DPA provides a definition of
‘personal data’;

“‘Personal data’ means data which relate to a living individual

  who can be identified –

 

(a) from those data, or

(b) from those data and other information which is in the

possession of, or is likely to come into the possession

of, the data controller,

              

  and includes any expression of opinion about the individual

  and any indication of the intentions of the data controller or

  any other person in respect of the individual”.

Accordingly, where a data controller holds information which is filed or
stored using reference numbers which directly relate to individual’s
names, and from which the individual in question can be identified, those
names and reference numbers would appear likely to constitute personal
data.

I trust this information is of some use.

Yours sincerely,

Jonathan Gray

Customer Service Manager

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http://www.ico.gov.uk or email: [email address]
Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF
Tel: 01625 545 700 Fax: 01625 524 510

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