Every field · Technical identifiers
IP address, device ID or cookie ID
Online identifiers are personal data (Recital 30). Tying them to a contact record is tracking and needs a cookie/consent basis.
personal data
personal data?
standard
sensitivity
needs a basis
AI use
legitimate interest for security; consent for tracking
lawful basis usually relied on
Keep it how long
Security logs: short (30 to 90 days). Tracking: with consent only.
The gap we see most
Web tracking IDs synced into the CRM contact record from a marketing tool with no consent record.
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