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David Siegel
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A piece of data that cannot be used to identify a natural person, and is not linked to a specific natural person is not PI under the GDPR or most other data protection laws (such as the CCPA). Therefore, such a datum does not need a lawful basis for processing, need not be included in notices of data collection provided to the user, is not subject to erasure requests, and generally is not subject to the protections that PI must get.

However, if the otherwise non-identifiable information is linked to a user's name or other PII, such as by being stored in the same DB record or a linked record, then it becomes PI. In short if there is a reasonable way to go from ma datum to PII, it is PI.

By the way one does not "use the user password to hash a salt". One normally appends (or otherwise combines) a salt to a password, and hashs the combined string, producing a hash value. Also, it is not really good security practice to use the hash oif a salted PW for anything but login or related security verification. If it i used to identify the user in other contexts, it increases the possibility of a security hole somewhere. The GDPR requires "appropriate" security measures be taken with PI, and introducing a hole by poor practice could violate that requirement.

David Siegel
  • 114.5k
  • 10
  • 212
  • 406