"It definitely is personal. But given that it's the output of more-or-less-random guesswork, maybe there's an argument that it's not actually data."
Yes, this. Creating inferences based on personal data such as a name can be wildly inaccurate and therefore not data as such. eg "Patrick", who phoned me earlier today claiming to be from an Essex based telecoms company with a Sheffield dialling code and a Bangalore accent. Clearly he was Irish!!
Biting the hand that feeds IT
