Collection Of Names And Email Addresses Constitutes A 'Database'

Author:Mr Ohad Elkeslassy
Profession:Herzog Fox & Neeman

We would like to bring your attention to the following:

On November 28, 2018 the Protection of Privacy Authority (the "PPA") issued a statement of opinion reflecting its position, according to which a list of names and email addresses constitutes a "database" as defined under the Protection of Privacy Law, 1981 (the "Law"). In its statement, the PPA determines that although the Law excludes a collection which includes only names, addresses and means of communication from the definition of a "database", a more suitable interpretation of the Law should be that if a person can be characterised based on his/her email address, the exclusion does not apply.

According to the opinion of the PPA, the reason for this position lies in the fact that in many cases it is possible to infer additional personal data regarding a person from the email address, which falls under one or more data types classified as "data" under the Law; for example, data regarding a person's "professional qualification" in case of work email address; data regarding a person's "personal status", when the email address is jointly owned by life partners, etc., information which necessarily signifies that the email address should not be classified as a mere "means of communication" as the exclusion under the Law stipulates. The PPA states that in recent years, email addresses have evolved into a "key" enabling the...

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