1. Question: identifiability of the data subject

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