Direct identifiers are pieces of data that allow to target a person, or a very small group of persons from a single data point. Indirect identifiers are anything that you could use to build a marketing cohort.
Combining a few indirect identifiers allows to target very specific groups of people. Or, using the very examples you quoted:
- The tuple (bank account number, country) is enough to target an individual.
- The tuple (full name, zip code) is enough to target a very small group of individuals. By adding just one more element you can identify individuals.[ß]
Each one of the four data points counts as user information under GDPR. Doesn't matter whether they are direct or indirect.
Disclosure: I wear the DPO hat at Smarkets. As a gambling company we are legally required to know quite a lot about our customers.
ß: For the nitpicking armchair lawyers: unless you happen to have a gated community for John Smiths.
https://ico.org.uk/media/for-organisations/documents/1591/pe...