Guidelines 08/2020 on the targeting of social media users – version for public consultation

Section 4.1 Users

18 Individuals make use of social media in different capacities and for different purposes (e.g. to stay in touch with friends, to exchange information about shared interests, or to seek out employment opportunities). The term “user” is typically used to refer to individuals who are registered with the service, i.e. those who have an “account” or “profile”. Many social media services can, however, also be accessed by individuals without having registered (i.e. without creating an account or profile). Such individuals are typically not able to make use of all of the same features or services offered to individuals who have registered with the social media provider. Both users and non-registered individuals may be considered “data subjects” within the meaning of Article 4(1) GDPR insofar as the individual is directly or indirectly identified or identifiable.

19 Whether or not individuals are expected to register with a real name or use a nickname or pseudonym may vary according to the social media service in question. It will generally still be possible, however, to target (or otherwise single out) the user in question even in the absence of a real name policy, as most types of targeting do not rely on user names but other types of personal data such as interests, sociographic data, behaviour or other identifiers. Social media providers often encourage users to reveal “real world” data, such as telephone numbers. Finally, it is worth noting that social media providers may also enable targeting of individuals who do not have an account with the social media provider.