Q&As

Are internet domain names considered ‘personal data’ for the purposes of the General Data Protection Regulation/Data Protection Act 2018?

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Produced in partnership with JP Buckley of DWF LLP
Published on LexisPSL on 07/01/2019

The following TMT Q&A Produced in partnership with JP Buckley of DWF LLP provides comprehensive and up to date legal information covering:

  • Are internet domain names considered ‘personal data’ for the purposes of the General Data Protection Regulation/Data Protection Act 2018?
  • Domain names
  • Definition of personal data
  • Relevant GDPR guidance

We do not have existing guidance which addresses your precise query, but hope the below will be useful for your research. For the purposes of this response we have limited our reply to the Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR) regime and those parts of the Data Protection Act 2018 (DPA 2018) which relate to that regime.

Domain names

A domain name is one of the components of the internet’s transport layer, being the internet’s naming and addressing system. Each computer or device that is connected to the internet is identified by an internet protocol address (IP address), such as 69.63.176.13. Because people find names easier to memorise than long strings of numbers, the domain name system evolved to help people locate resources on the internet. In this example, 69.63.176.13 is facebook.com.

For further guidance on domain names generally (eg including on how the WHOIS service has adapted for compliance with the GDPR), see: Domain names—overview and the Practice Notes and other guidance in: Domain names—overview, including, for example, Practice Notes: Domain names—background, registration and dispute resolution, WHOIS: How to find information about domain names and News Analysis: Generic top-level domain registration data and the temporary specification.

Definition of personal data

As explained in Practice Note: Key definitions under data protection law, t

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