[At-Large] GDPR and Google Analytics - Oh No You Don't, Austrian DPA says.....

Carlton Samuels carlton.samuels at gmail.com
Tue Jan 18 16:40:20 UTC 2022

The chickens are coming home to roost...

  ” *…the use of IP addresses, cookie IDs, advertising IDs, unique user IDs
or other identifiers to (re)identify users do not constitute appropriate
safeguards to comply with data protection principles or to safeguard the
rights of data subjects. This is because, unlike in cases where data is
pseudonymised in order to disguise or delete the identifying data so that
the data subjects can no longer be addressed, IDs or identifiers are used
to make the individuals distinguishable and addressable. Consequently,
there is no protective effect. They are therefore not pseudonymisations
within the meaning of Recital 28, which reduce the risks for the data
subjects and assist data controllers and processors in complying with their
data protection obligations.*”



*Carlton A Samuels*

*Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround*
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