Communications Data (CD) Section 261
The IPA 2016 provides the definition of CD for the purposes of acquiring such data under Part 3 and retention under Part 4. That definition of CD is made up of "Entity data" (for example, phone numbers or other identifiers linked to customer accounts) and "Events data" (for example, the fact that someone has sent or received an email, phone call, text or social media message and the location of a person when they have made a mobile call or used a Wi-Fi hotspot), with a carve-out to exclude the "Content" of a communication.
	Insufficient clarity existed over whether subscriber and account data was CD or content, for example in the context of registration details provided in online forms when an individual was setting up an account or taking up a service over the internet.
	Due to the complex nature of whether subscriber and account data amounted to CD or content, this Act amends s261 IPA 2016 with the intention of removing any potential ambiguity. This change aims to provide a clear basis for the acquisition of subscriber and account data as CD and also aims to make it clearer when an error has occurred.
	The amendments to section 261 covering "subscriber data" and "content" do not affect the oversight function of IPCO which continues to inspect and highlight any errors.