The chickens are coming home to roost... ” *…the use of IP addresses, cookie IDs, advertising IDs, unique user IDs or other identifiers to (re)identify users do not constitute appropriate safeguards to comply with data protection principles or to safeguard the rights of data subjects. This is because, unlike in cases where data is pseudonymised in order to disguise or delete the identifying data so that the data subjects can no longer be addressed, IDs or identifiers are used to make the individuals distinguishable and addressable. Consequently, there is no protective effect. They are therefore not pseudonymisations within the meaning of Recital 28, which reduce the risks for the data subjects and assist data controllers and processors in complying with their data protection obligations.*” https://techcrunch.com/2022/01/12/austrian-dpa-schrems-ii/ Carlton ============================== *Carlton A Samuels* *Mobile: 876-818-1799Strategy, Process, Governance, Assessment & Turnaround* =============================