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1.3.1.1 Direct personal data

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Direct personal data is data that can be attributed directly to a specific data subject without the use of additional information. For instance, the data subject’s photo, DNA or fingerprints. A name can be direct personal data if it is a rare one, like Helen Mirren. There is no need to add “the actress” to that name, as she is the only person by that name (and actually Helen Mirren was born with the last name Mironoff, which her Russian father anglicized). Most names are not a unique identification of a person, and hence not direct personal data. A unique title, such as “the current prime minister of France”, or “Simon, Earl Nelson” are direct references to an individual, thus direct personal data.

Privacy and Data Protection based on the GDPR

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