Mr. Dale Sunderland:

One needs to look at a case-by-case assessment. I probably need to reflect on it, but one cannot just assume that who the person's siblings are is necessarily the person's personal data. It is a complex situation and the further one moves out, the less of a link there is. Personal data has to relate to the person as an individual and, through direct or indirect means, the person can be identified from that data. It would be hard to envisage a situation where the name of one's sibling or who that is would be constituted as one's personal data. It is different in the context of a direct relationship between a parent and the child specifically where that personal data is recorded on a birth certificate. It is a complex question and I am afraid that I am probably not going to be able to answer it in full today. It would be my general position that one could not automatically say that information about a sibling is one's personal information. There may be certain cases where that is the case, but it would have to be looked at on a case-by-case basis, to look at the link and whether there is any joint or mixed data. There is a difference between mixed data and what can be constituted as one's personal data. There can be a context where there is mixed data, for example, a bank account. A spouse's data may be included in the same bank account details as the person's in terms of a joint account, but that does not per semean that one's spouse's data is one's personal data. That is a practical example of where that might arise. I will leave it at that.