[mbrookes]

Let's not confuse Personally Identifiable Information (PII) the US definition, with Personal Data, the EU definition. From the UK ICO [1] "Personal data is information that relates to an identified or identifiable individual. (Emphasis mine.)

So, if it is possible to correlate the personal data with other records that identify an individual (whether by you or a third party with whom the data is shared) it is personal data.

Full disclosure: I work for Veritas Technologies, which, among many other things, provides technologies that help companies find, filter and take action on PII and personal data. Opinions shared here are my own, and do not necessarily represent the views of my employer.

[1] https://ico.org.uk/for-organisations/guide-to-data-protectio...