# CJEU - C-654/25 - Undelam

- Type: Case Law
- Source: CJEU
- Identifier: C-654/25
- Date: 2026-11-09
- Original: https://gdprhub.eu/index.php?title=CJEU_-_C-654/25_-_Undelam
- Canonical: https://overview.legal/posts/607866
- Topics: Personal Data

## Summary

1. Question: identifiability of the data subject. 1. Question: identifiability of the data subject . According to Advocate General Szpunar (AG), data is personal data pursuant to Article 4(1) GDPR when the entity that processes the data can identify the data subject by combining the personal data in question with other data, using the means accessible to them or to third persons. The question of identifiability is to be assessed not from an objective perspective, but from the perspective of the

## Full text

1. Question: identifiability of the data subject. 1. Question: identifiability of the data subject . According to Advocate General Szpunar (AG), data is personal data pursuant to Article 4(1) GDPR when the entity that processes the data can identify the data subject by combining the personal data in question with other data, using the means accessible to them or to third persons. The question of identifiability is to be assessed not from an objective perspective, but from the perspective of the entity that has access to the data (subjective approach). The abstract possibility that someone is capable of identifying the data subject is not sufficient. According to Advocate General Szpunar (AG), data is personal data pursuant to Article 4(1) GDPR when the entity that processes the data can identify the data subject by combining the personal data in question with other data, using the means accessible to them or to third persons. The question of identifiability is to be assessed not from a

## Cited law provisions (2)

### GDPR — gdpr-art-4-par-1-en

‘personal data’ means any information relating to an identified or identifiable natural 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;

### GDPR — gdpr-art-82-en

Right to compensation and liability

---
Generated by overview.legal · https://overview.legal/posts/607866 · 2026-11-14