GDPR: PII Data vs. Personal data


The European Union’s new General Data Protection Regulation (GDPR), which goes into full effect in May 2018, significantly strengthens the data privacy rights of consumers and the requirements on companies that solicit and retain customer identities. Positive part about GDPR is that companies cannot hide, and It applies to all companies anywhere in the world those do business in Europe and/or retain EU citizen’s data.

The US-based Personally identifiable information (PII) and the European concept of Personal Data make up a critical demarcation line related to data types and privacy consequences. To get compliant with GDPR, one has to understand the difference between the way two-legal systems approach the concept of personal information and its meaning in the context they are used. PII is any data that could potentially identify a specific individual. Any information that can distinguish one person from another and can be used for de-anonymizing anonymous data can be considered PII.

PII, or SPI (sensitive personal information), as used in information security and privacy laws, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. PII term is used in US context that is created on the basis of commonly used US law. Examples of PII data–full name, maiden name, social security number, phone number, email address, asset information, owned properties etc. Little variation may be observed from states to states.

Personal Data is defined in the EU Directive 95/46/EC and it covers much wider range of information that may include transaction history, social media posts, photographs and other data that relates to an individual or identifiable person, directly or indirectly. Personal data term applies to all 28 EU states of European Economic Area (EEA). The concept reflects European law maker’s intention to bring the concept of privacy as a fundamental human right and draw the accountability of handling this sensitive data by business.

We can say all PII data is personal data but not all personal data is PII data. It is important that data and IT architects along with Data Protection Officer (DPO) consider personal data beyond the narrow scope of PII, especially US based companies, to build a successful GDPR compliance program.