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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