user account

The rules define a "user account" as the online account that a Data Principal (the individual to whom the personal data relates) registers with a Data Fiduciary (the entity that decides how and why data is processed). This definition goes beyond just a traditional username and password combination. It specifically includes a wide range of digital identities. A user account covers profiles, pages, handles, email addresses, mobile numbers, and other similar online presences. The key requirement for these items to be considered a user account is that they must be the method the Data Principal uses to access the services provided by the Data Fiduciary. By listing these specific examples, the rule ensures that modern ways of logging in or interacting with a service are legally recognized as a user account.

Key points

• A user account is the online account registered by the Data Principal with the Data Fiduciary (Rule 2(1)(c)).
• The definition broadly includes profiles, pages, handles, email addresses, and mobile numbers (Rule 2(1)(c)).
• These digital presences count as a user account if they are the means by which the Data Principal accesses the Data Fiduciary's services (Rule 2(1)(c)).

Common misreadings

• A reader might think a user account only means a traditional login portal, but the rule explicitly includes mobile numbers, email addresses, and handles used to access a service.