DPE-2026-0031

E-mailadres als sleutel tussen diensten

Een adres dat voor contact is gegeven, gaat door naar andere partijen, plat of als hashwaarde, zodat zij dezelfde persoon herkennen.

Familie
Keten
Status
actief
Geldt voor
web, mobile-app, api

Wat er gebeurt

An address the person supplied for a purpose of their own, an account, an order, a newsletter, is used as a key. It is sent to other parties in the clear or, more often, as a hash of the address in lowercase with the spaces trimmed. The hash protects nothing here: any party that already holds the address computes the same value, which is precisely why that form is used. Neither side has to exchange anything with the other, because both derive the same key from a value the person handed over once.

Waarom het ertoe doet

An address is stable for years and follows the person across devices, browsers and applications. A cookie can be cleared; this cannot. It joins what someone did on one service to what they did on another, and usually to a name, because an address is rarely anonymous. It was given in order to be reached, not in order to be recognised elsewhere.

Veelvoorkomende oorzaken

  • an advertising tag configured to send the address field on form submission, for audience matching
  • a customer list uploaded from server to server for matching against a platform's own users
  • an identity resolution component added through a tag container
  • a login form that hashes the address in the browser and sends it onward in the same step

Dit is het níet

Text the visitor typed appearing in a request as content is User input to third parties; there the content itself is what travels. Here the address is used as a key, it may be hashed, and it may travel from a server rather than from the browser. Two parties exchanging identifiers of their own is Identifier synchronisation between parties; here no exchange is needed, because both sides can compute the same value from the address. An internal account identifier travelling to a party that also holds its own identifier for the browser is Account identity joined to a tracking profile; that value is minted by the operator, this one is derived from the address itself.

Hoe je het vaststelt

Indicator

A request to a host under a different registrable domain containing the address entered, or the MD5, SHA-1 or SHA-256 of that address in lowercase and trimmed, in hexadecimal or base64. Compute the hashes of the test address before measuring and search the capture for those strings.

Methode

network-with-identifier

Kwaliteit van de detectie

95 van 100

De grenzen van deze bevinding

Wat dit patroon zou weerleggen

  • The matched value is a hash of something other than the address, shown by recomputing the hash of the exact address against the captured value.machinaal te toetsende bevinding vervalt
  • The address travelled to a party executing a step the person asked for, such as delivering the message or the order.met de hand te toetsende bevinding vervalt
  • The recipient acts only on the operator's instruction and does not use the value to recognise the person elsewhere.niet uit de meting af te leidende bevinding wordt zwakkerThe transfer is visible in the capture; the purpose is not. A processing agreement of the same date is what settles it.
  • A refusal registered in the consent state removes the request.machinaal te toetsende bevinding wordt zwakkerThe mechanism is then present but gated, which is a different finding from an ungated one and is worth stating as such.

Wat dit patroon níet vaststelt

  • harm; the catalogue standardises a finding so it can be referred to, it does not weigh it
  • severity; there is no score here, by design. Weighing belongs to whoever applies the entry to a concrete case
  • unlawfulness; that is for a supervisory authority or a court
  • intent; a fault is usually a build decision, not a plan
  • absence: not finding it in one capture is not evidence that it is not there

Reproduceren

  • manualMETHOD.mdno dedicated reproduction exists yet; follow the general method and the indicator above

Juridisch kader

Bepalingen

eu-gdpr-5-1-beu-gdpr-6-1-aeu-gdpr-13

Veelgehoorde tegenwerpingen

It is hashed, so it is not personal data.

A hash of an address is a pseudonym, not anonymity: every party that holds the address computes the same value, and that is exactly why it is sent. If it did not identify, it would not work.

It is our own customer data.

It is, until it leaves. The objection is not to holding the address but to using it as a key at another party, for a purpose it was not given for.

It is only for suppression, so we do not advertise to existing customers.

That purpose is testable. Suppression is a list matched once; it does not require the address to travel on every form submission or every page view.

The recipient deletes it after matching.

The value it matched on is the same value the person has everywhere else, so the match persists in the profile whether the input is deleted or not.

Geldt wanneer

to-processing

Verwante patronen

← alle patronen