Personal data means any information relating to an identified or identifiable natural person. In this context, not only information that allows the person to be definitively identified, such as their name, surname, date of birth and place of birth, but also information about the person's physical, family, economic, social and other characteristics is personal data.
A person being identified or identifiable means that the person can be made identifiable by linking the existing data to a natural person in any way. In other words, it covers all cases where the data carries concrete content expressing the person's physical, economic, cultural, social or psychological identity, or where the person can be identified as a result of linking the data to any record such as an identity, tax or insurance number. Data such as names, phone numbers, vehicle license plates, social security numbers, passport numbers, CVs, pictures, images and audio recordings, fingerprints and genetic information are personal data because they can make the person identifiable, even if indirectly.
Personal Data in General
The concept of personal data is defined in the law as “any information relating to an identified or identifiable natural person”. Accordingly, the concept of personal data has four elements:
- Identified or identifiable
- Natural person
- Relating to
- Any information
This definition in the law is in line with the European Union Directive frequently referred to in the Justice Committee Report. In this context, the explanations below have been written as a summary of Opinion 4/2007 of the Article 29 Working Party.
“Identified or identifiable”
For a person to be considered “identified”, they must be distinguishable from the other members of a group they are in. Accordingly, the expression “identifiable” means that, although the person's identity has not yet been determined, it is possible to determine it. As can be understood, the lower threshold for meeting this element is being “identifiable”.
