Lets say I have a bookmark file which contain list of urls. It is associated with one user account. Its likely associated with one person but I cannot identify that person. There is no other information associated with the user account. Is the bookmark file personal data ?
I would go with "better safe than sorry" if I had to manage this sort of data. It might be fine so long as the URLs are all non-identifying stuff like the Wikipedia home page. But I bet I would have users with much more revealing bookmarks, like, say, their Keybase profile page, or URLs with session/auth tokens in query strings, or the home page of their church which has a congregation of less than 50 people.
Another way to phrase this question is “what use is the bookmark file without a user to use it?”
I don’t think there’s anything wrong with storing anonymous data: a log of bookmarked urls for instance. So long as there’s no way to trace back who they belong to if that person wants to be forgotten.
In general, it's probably even sensitive personal data. A list of URLs can potentially identify a person's religious beliefs, sexual orientation, political views etc.
> A list of URLs can potentially identify a person's religious beliefs, sexual orientation, political views etc.
But can he be identified ? I believe if its too difficult to identify using even "religious beliefs, sexual orientation, political views etc" then its not personal data. Though I cant seem to find link to the page where I read it.
On similar note, even IP _alone_ appears to be non personal data if since it cannot identify a person [1].
From Case 582/14 – Patrick Breyer v Germany [2]
On appeal, the Regional Court of Berlin (the "Kammergericht") ruled that IP addresses in the hands of website operators could qualify as personal data if the relevant individual provides additional details to the website operator (e.g., name, email address, etc.) in the course of using the website.
Lol even German Govt cant seem to figure out its own laws. They should have gone to one of those consultants.
