Clearly this must be the case if they are referred to by name. Names, however, are an inefficient form of identifier. A glance at any telephone directory will reveal the number of people who share the same or a similar name. Even a single person may be referred to in a variety of ways using various combinations of names and initials. It is also possible that individuals may, quite lawfully, determine to change their name.
Numbers provide a more accurate form of identifier.
In some countries individuals are allocated a personal identification number at birth, this number being used throughout the individuals life. In terms of administrative efficiency, such a system offers many advantages. It also offers the prospect of very efficient correlation of information held by a number of parties and in a number of countries proposals for the introduction of such a system have been dropped following public criticism of the adverse implications for individual privacy. No single system of personal identifiers operates in the United Kingdom, but there is no doubt that where information is held by reference to bank account numbers, national insurance numbers or any other form of identifier, the Act will apply. The question whether an individual is to be considered identifiable is also linked to the definition of processing.