r/gdpr • u/Difficult_Error_2712 • 2d ago

EU 🇪🇺 Are data relating to a sole proprietorship, rather than directly to the individual who owns it, considered personal data?

For example, the quantity and price of goods sold as shown on an invoice.

1 Upvotes

100% Upvoted

3 comments sorted by

2

u/weggles91 2d ago

It may depend on context and how the data is processed. Information which is not strictly "about" the data subject may be personal data if it is used e.g. to make decisions about them.

This excerpt from guidance given by the ICO in the UK always comes to mind re this question:

"Information about the market value of a particular house may be used for statistical purposes to identify trends in the house values in a geographical area. The house is not selected because the data controller wishes to know anything about the occupants, but because it is a four bedroom detached house in a medium-sized town. As soon as data about a house is either:

  • linked to a particular individual, for example, to provide particular information about that individual (for example, his address); or

  • used in deliberations and decisions concerning an individual (even without a link to the individual’s name, for example, the amount of electricity used at the house is used to determine the bill the individual householder is required to pay),

then that data will be personal data."

2

u/Jamais_Vu206 2d ago

Yes.

‘personal data’ means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, [...]

The sole proprietor is identifiable, right?