Two years of GDPR: Clarifying personal data [Infographic]

03 Feb 2020

Two years of GDPR: Clarifying personal data [Infog...


The 25th May 2020 will mark the two-year anniversary of the implementation of the General Data Protection Regulation, also known as the GDPR (and sometimes referred to as the bane of your DPO’s existence).

Thankfully, there is now more clarity around the requirements of GDPR, versus those halycon days of uncertainty where everyone rushed to understand the implications of the forthcoming regulation. However, we’ve noticed that there are still some areas frequently catching organisations out.

One of these areas is personal data and—as many organisations will use the two year anniversary as a prompt to review their information asset registers and privacy impact assessments—we felt it might be timely to look at some of the areas of personal data which can be overlooked.

Clarifying personal data

Firstly, let’s look at what the GDPR defines as ‘personal data’. Broadly speaking, there are two categories of personal data:

Personal data (also referred to as Personally Identifiable Information or PII) is any information that can be used to directly identify an individual, or information that can be used to identify an individual in combination with other information. Examples include name and surname, personal email address and an individual’s National Insurance number.

Sensitive personal data is a special category of personal data that must be treated with extra security as its disclosure is more likely to cause harm to the individual. Examples include information about an individual’s sexuality, their political beliefs, medical history and biometrics.

Common myths about personal data

So far, so good! Now we’re clear on the definitions, there are some common misconceptions that we should be aware of:

Myth 1: Pseudonymised information is not considered personal data

What is the real story? Pseudonymised information is considered personal data by the GDPR. Organisations will sometimes attempt to anonymise information by replacing personal data with a code. For example, a list of customers may have the first and last names replaced with a numerical code - maybe ‘Client001’, ‘Client002’ and so on. Whilst the phrase ‘Client001’ may not represent personal data, when used as an identifier for an individual, there is a chance that an unauthorised third party may be able to link the code back to the individual. It is for this reason that the GDPR considers pseudonymised information to be personal data.

Myth 2: Consent is really straight forward

The GDPR introduced strict guidelines around what constitutes consent. Under the GDPR, all consent to process the personal data of an individual must be explicit. In practice, this means that when you ask for the consent of an individual, they must clearly agree to the processing of their information and demonstrate this approval. Implied consent (e.g. offering a check box to the individual that is pre-ticked) is a definite no-no!

So, we’re fine as long as we explicitly ask the individual to confirm that they are happy for us to process their personal information? Not exactly. The GDPR makes a distinction based on age and states that ‘children’ must have consent provided on their behalf by whoever holds parental responsibility for the child. It is important to note that the age that an individual is permitted to provide consent for themselves can vary depending on the country’s data protection laws. In the UK, this age is 13.

Important note: Individuals under the age of 13 are considered to be incapable of providing consent by the GDPR.

Myth 3: IP Addresses aren’t considered personal data

What is the real story? An IP address is considered personal data by the GDPR.

IP Addresses are commonly overlooked by organisations. Despite the fact that many users may “share” a single IP address, in addition to the likelihood that an individual’s IP address is dynamic and subject to change over an extended period of time, the GDPR classifies an IP address as personally identifiable information. If you collect IP addresses for any purpose, it is important to treat them in the same way you would other personal data.

It is important that all employees understand what constitutes personal data and sensitive personal data. To help communicate this message, we’ve produced a personal data factsheet, which provides an explanation of personal data and some common examples.

How PGI can help with GDPR compliance

For many organisations, the first step in ensuring your organisation is complying with the GDPR is to determine what, if any, personally identifiable information your organisation collects and whether you are acting as a controller or a processor.

Our Information Assurance team are experienced in implementing and auditing a wide range of regulatory compliance frameworks, including GDPR, ISO 27001 and PCI DSS. We will work with you to determine what you need, so you’re only spending what you must.

If you would like to discuss how we can help you meet your requirements, please contact us for a discussion: Call on +44 (0) 845 600 4403 or email us via

Click the image to download a PDF version.


Your free global geopolitical
risk dashboard

PGI’s Risk Portal tool provides daily intelligence feeds, country threat assessments and analytical insights, enabling clients to track, understand and navigate geopolitical threats.

The Risk Portal gives users up-to-date information and analysis on global affairs.

The Risk Portal allows users to visualise information in a unique and instantly understandable way. Mapping filters enable the visualisation of incidents by threat category, time period, perpetrator and target type.

Risk Portal users can upgrade their accounts to include the Report Builder and Country Profile Generator features. The Report Builder allows users to select information, data and images from the Risk Portal and create bespoke reports and emails.

Subscribers to PGI’s Bespoke services receive tailored analysis on specific sectors and geographies of interest, delivered at a frequency they determine.

Visit the Risk Portal

GDPR Services

Making ongoing compliance easier for you and your business

GDPR is now in force. Make sure your business meets the necessary requirements, providing assurance for all of your customers and employees.

PGI GDPR Services

A full audit of your business to assess the level of your compliance against GDPR requirements.

Become GDPR compliant with minimal work. We will conduct an analysis, review, report and implement any necessary changes to your business.

We will conduct simple security assessments to help you understand and mitigate the potential risks to your business.

Find out more on GDPR

Compliance Services

Get your business ready to face the cyber challenge.

We provide a full range of accredited, certified and bespoke services that assess the resilience of your cyber security posture.

PGI GDPR Services

PGI’s Qualified Security Assessors (QSA) will help you meet Payment Card Industry Data Security Standards (PCI DSS).

Find out more on PCI DSS

Demonstrate your commitment to cyber security by achieving and maintaining accreditation for the globally-recognised information security standard.

Find out more on ISO 27001

Expert assistance on the implementation and maintenance of governance requirements for personal data.

Find out more on GDPR

Find out more on Compliance

Vulnerability Testing

Understand the threats of phishing and malware to avoid being targeted.

Undertake our phishing vulnerability assessment to reduce your organisation’s risk of attack, by measuring the cyber awareness of your workforce.

Malware & Phishing Services

PGI will conduct a tailored phishing campaign, using multiple methods, to identify realism and train employees where necessary to mitigate future attacks.

PGI monitor multiple metrics to identify the types of phishing, generate in-depth analytical reports and provide an informed decision to help improve your organisation’s level of security and awareness.

Find out more on Vulnerability Testing

Cyber Security

Prevent attacks, respond to breaches and protect your business.

Our bespoke range of cyber security services not only protect your critical assets but provide the education you need to keep your operations and data safe.

Cyber Security Services

Implement this cost-effective cyber security measure launched by the government to prevent cyber-attacks, demonstrate information security commitment to your clients, and attract new business by being recognised as a secure organisation.

Find out more on Cyber Essentials Accreditation

The most effective way to identify how attackers target your organisation’s weaknesses is by evaluating your system, your network security, and reporting on any vulnerabilities that could have an impact on your business.

Find out more on Penetration Testing

If your business has experienced breaches, network compromises or operational disruption, our team of cyber security specialists can deploy quickly, and will begin the process of detecting and eliminating the threat efficiently.

Find out more on Data Breach Response & Recovery

In the event of a computer security investigation, a vital part of the response process is making a copy of your data for safe forensic analysis. We will work with you to preserve and use this evidence to discover the extent of an intrusion.

Find out more on Digital Forensics

Browse our Cyber Security services

Data Breach Response & Recovery

We prevent attacks, respond to security breaches, and protect your business

Our team of specialists can deploy quickly and efficiently to begin the process of detecting, eliminating and preventing future threats of a breach.

Malware & Phishing Services

A vital part of the response process is making a copy of your data for safe forensic analysis. We will work with you to preserve and use this evidence to discover the extent of an intrusion.

Find out more on Digital Forensics

We will identify and minimise the risks, as well as the possibility of future risks to your business.

Consistent interaction with your management team and recommendations on how to approach all outcomes that need attention.

Find out more on Data Breaches

Subscribe to our Cyber Bytes Newsletter

Keep yourself in the loop with PGI by signing up to our Monthly Cyber Bytes email. You will receive updates, tips and narrative around what has been happening in the world of information security.

Get in touch today

For more information on how we can help you or your business, please contact us via:

Related News

International Womens Day - Pioneering Women in Tec...

08 Mar 2017

Pioneering Women in Technology – Katherine JohnsonThe Oscar season has been and gone. The...

Read news article

Law Firms and why they need cyber security

07 Sep 2018

Why Law Firms need Cyber Security. Suffering a data breach can be devastating! From the experts at P...

Read news article

Content from the expert - GDPR and Cyber Governanc...

12 Jul 2017

Will there be a knock on effect regarding the General Data Protection Regulation (GDPR) after the UK...

Read news article
Back to the News Hub

+44 (0)207 887 2699
©2019 PGI - Protection Group International Ltd. All rights reserved.
PGI - Protection Group International Ltd is registered in England & Wales, reg. no. 07967865
Address: Unit 13/14, Swallow Court, Sampford Peverell, Tiverton, England, EX16 7EJ