What are the legal definitions of personal data concerning phone numbers?

[muskanhossain]

The legal definition of personal data concerning phone numbers varies across jurisdictions, but generally includes any information that relates to an identified or identifiable natural person. A phone number, in most contexts, directly identifies an individual or can be used in conjunction with other data to do so, thus falling under the definition of personal data.


Here's a breakdown of how different legal frameworks define personal data in relation to phone numbers:

1. General Data Protection Regulation (GDPR) (European Union):
Article 4(1) of the GDPR defines "personal data" as:

"any information relating to an identified or identifiable natural japan whatsapp number data person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person."

A phone number is explicitly considered an identifier that can directly identify a natural person. Therefore, under GDPR, a phone number is unequivocally personal data. The GDPR also covers metadata associated with phone numbers, such as call logs or communication patterns, if they can be linked to an identifiable individual.


2. United Kingdom General Data Protection Regulation (UK GDPR):
The UK GDPR mirrors the EU GDPR in its definition of personal data, including phone numbers as a direct identifier of an individual.

3. California Consumer Privacy Act (CCPA) (United States):
The CCPA defines "personal information" as information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This includes:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver's license number, passport number, or other similar identifiers. While "phone number" isn't explicitly listed as a unique personal identifier, it would likely fall under this category as it can be used to identify or be associated with a particular consumer.
4. Personal Data Protection Act, 2023 (Draft, Bangladesh):
As of May 2025, Bangladesh's dedicated Personal Data Protection Act is still in draft form. However, the drafts have included definitions of "personal data." Typically, these definitions are broad and encompass any information relating to an identifiable individual. Phone numbers, being a direct means of identifying and contacting an individual, would almost certainly be classified as personal data under this prospective law.

The draft 2023 version defined "personal data" to mean:

"any information relating to the physical, mental, or emotional characteristics of the data subject, such as facial expressions, fingerprints, iris scans, voiceprints, digital radiographs, or any other sensitive personal data which is capable of..."

While this definition focuses on sensitive personal data with examples, the broader understanding within data protection principles is that any information that can identify an individual, directly or indirectly, constitutes personal data. Subsequent iterations of the draft act are expected to clarify and broaden this definition to align with international standards, explicitly including identifiers like phone numbers.

In Conclusion:
Across various legal frameworks, including the GDPR, UK GDPR, CCPA, and the anticipated PDPA in Bangladesh, phone numbers are considered personal data. This classification triggers various obligations for those who collect, process, and store this information, including requirements for lawful processing, security measures, and respecting the rights of individuals concerning their personal data. The specific nuances and requirements may differ between jurisdictions, but the fundamental recognition of phone numbers as personal data remains consistent.