Re:Judge orders Google to turn over a full year of actor’s data
by tjoff on Thursday January 09, 2020 @09:39AM
(#22001510)
It depends on the context. An ISP can trivially map an IP to a person.
So can Amazon/whoever if they saved the IP alongside other customer information.
But a naked ip->person lookup would require a warrant.
While the wording of the Recital leaves some ambiguity as to whether an IP is automatically Personal Data under the GDPR, its specific call-out would make arguing that it is not difficult. This would particularly be the interpretation of American lawyers, who tend to assume that no connection is too tenuous to be held against their client by a shrewd prosecutor or regulator and will thus advise their client to treat all IPs in all situations as Personal Data.