IP addresses are considered personal data under GDPR. Understanding your compliance obligations is essential when using IP-based security measures.
Are IP Addresses Personal Data?
The European Court of Justice has ruled that IP addresses can constitute personal data when they can be linked to an identifiable individual, directly or indirectly.
This means dynamic IPs assigned to households, static IPs assigned to businesses, and IPs in access logs are all potentially personal data requiring GDPR compliance.
Important Note
This article provides general information, not legal advice. Consult with a qualified legal professional for specific GDPR compliance guidance.
Lawful Basis for Processing
To process IP addresses legally, you need a valid lawful basis:
- Legitimate Interests - Network security is recognized as a legitimate interest, but requires balancing against data subject rights
- Legal Obligation - Some security logging may be required by law or regulation
- Contract Performance - Necessary for service delivery in some cases
Best Practices
- Document Your Basis - Record why you collect and process IP data
- Minimize Data - Only collect IP data necessary for security purposes
- Set Retention Limits - Delete IP logs when no longer needed for security
Fraudcache and GDPR
Fraudcache processes IP addresses as a security service. We publish only publicly-observed IPs associated with malicious activity, not personal browsing data or individual identification.
Review Our Data Practices
Learn more about how Fraudcache handles IP data.