Are IP Addresses Considered Personal Data?

Yes, under the GDPR and similar privacy frameworks, IP addresses are generally treated as personal data. This is because they can be used to identify a person either directly or in combination with other data, even if they don’t immediately reveal someone’s identity on their own.

The GDPR defines personal data as any information that relates to an identified or identifiable individual. This includes online identifiers like IP addresses, which can be used to trace the activity of a user or device over time. While an IP address by itself may not reveal a person’s name or contact details, it can still serve as a key to identifying someone when paired with other information, such as subscriber details held by internet service providers.

A key case in this area is the Breyer ruling by the European Court of Justice, which confirmed that dynamic IP addresses, (those that change with each session), can still be considered personal data if the website operator has a legal route to obtain additional identifying information, such as through cooperation with an ISP. Static IP addresses, which remain fixed and are tied to specific devices or users, are even more clearly classified as personal data because they can more easily be linked to an individual.

In practice, this means that collecting or processing IP addresses, whether for analytics, logging, or marketing, falls within the scope of data protection law. If the data can be reasonably associated with a person or household, even indirectly, it must be handled in accordance with GDPR requirements, including transparency, purpose limitation, and in many cases, obtaining user consent.