However, if you could at any point use any reasonably available means to re-identify the individuals to which the data refers, that data will not have been effectively anonymised but will have merely been pseudonymised. In order to be truly anonymised under the GDPR, you must strip personal data of sufficient elements that mean the individual can no longer be identified. There is a clear risk that you may disregard the terms of the GDPR in the mistaken belief that you are not processing personal data.
You should therefore ensure that any treatments or approaches you take truly anonymise personal data. Organisations frequently refer to personal data sets as having been “anonymised” when, in fact, this is not the case. Ou should exercise caution when attempting to anonymise personal data. Similarly, the United Kingdom Information Commissioner’s Office (ICO) provides a warning regarding companies attempting to meet the GDPR’s standard for anonymization, stating: The International Association of Privacy Professionals (IAPP) has also provided guidance on the definition of anonymization, which states that achieving true anonymization may be nearly impossible-especially considering that a recent study showed that the majority of the United States’ population could be personally identified using three data points (zip code, date of birth, and gender). Īccording to the guidelines, this possibility extends to “indirect” identification, i.e., if identification could be possible by using pieces of information to narrow down the group to which the person belongs (age, occupation, place of residence, IP address, etc.). Accordingly, the natural person is “identifiable” when, although the person has not been identified yet, it is possible to do it. In general terms, a natural person can be considered as “identified” when, within a group of persons, he or she is “distinguished” from all other members of the group. Īchieving this level of anonymity is made more difficult by guidance published by the European Data Protection Board, which states that the test for whether a person is “identifiable” does not necessarily mean that an actual subject is identified-just that it would be possible to identify the subject: To ascertain whether means are reasonably likely to be used to identify the natural person, account should be taken of all objective factors, such as the costs of and the amount of time required for identification, taking into consideration the available technology at the time of the processing and technological developments. To determine whether a natural person is identifiable, account should be taken of all the means reasonably likely to be used, such as singling out, either by the controller or by another person to identify the natural person directly or indirectly. This sounds simple, but it is actually not when considering whether the exposed data (what remains after anonymization) can be paired with other available information to deduce the identity of data subjects. To achieve anonymization under GDPR, re-identification of a data subject (even by the company that anonymized the data ) must be impossible. The principles of data protection should therefore not apply to anonymous information, namely information which does not relate to an identified or identifiable natural person or to personal data rendered anonymous in such a manner that the data subject is not or no longer identifiable. AnonymizationĪccording to GDPR Recital 26, anonymized data does not fall within the GDPR at all because data is no longer considered “personal data” following anonymization:
ANANEMI SATTIM HOW TO
The challenge of using either method is feasibility: whether a method is practical, able to achieve compliance, or ultimately less burdensome than other available means of processing or transferring data under the GDPR, and how to apply such method. This type of data may enjoy fewer processing restrictions under the GDPR.
Pseudonymization replaces personal identifiers with nonidentifying references or keys so that anyone working with the data is unable to identify the data subject without the key. Anonymized data is excluded from GDPR regulation altogether because anonymized data is no longer “personal data.” Two potential methods are worthy of examination.Īnonymization eliminates personal data so that data subjects can no longer be identified. This installment of The eData Guide to GDPR examines two methods for compliance.Ĭompanies that regularly do business in Europe understandably look for ways to lessen their burden regarding compliance with the GDPR. Compliance with the regulation’s requirements can be challenging for many organizations and its potential fines daunting.
The EU General Data Protection Regulation (GDPR) regulates the use of personal data collected from European data subjects, including activities of non-European companies that target or process European data subject personal data.
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