What counts as personal data
Is a phone number personal data?
- Short answer
- Yes, in almost every practical case. A mobile number is tied to an identified individual through the telecom KYC process, so it identifies a person even without a name attached. Treat any customer or employee number as personal data.
The test is whether the individual is identifiable by or in relation to the data. A number on its own, held by a business that also knows who it called, plainly identifies someone.
This matters most for marketing lists and CRM exports, which are often thought of as contact data rather than personal data and are shared casually with agencies as a result.
A landline for a business switchboard is a weaker case, but the volume of such numbers in a typical database is small compared to mobile numbers.
Where this comes from
- Section 2(t), DPDP Act 2023
The mistake people make
Sharing phone lists with a call centre or marketing agency without a processing contract, on the basis that numbers are not really personal data.