The Scope of “Personally Identifiable Information” Is Changing

It is easier than ever to identify a consumer with just a few pieces of seemingly innocuous information.  Advances in big data analytics, combined with the increasing volume of data generated by consumers in their daily lives, have “increasingly blurred [the] line” between personally identifying information (PII) and non-PII, according to a recent speech by Federal Trade Commission (FTC) Chairwoman Edith Ramirez.  She expanded on her point by expressly stating that the FTC “now regard[s] data as personally identifiable when it can be reasonably linked to a particular person, computer, or device.”  According to the Chairwoman, “[i]n many cases, persistent identifiers, such as device identifiers, MAC addresses, static IP addresses, and retail loyalty card numbers meet this test.”

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