Pseudo-Anonymized Data
Definition
Personal data that has undergone pseudonymization processing to replace direct identifiers with artificial identifiers, making it more difficult but not impossible to identify individuals. This term is sometimes used interchangeably with pseudonymized data, though it emphasizes that the data maintains characteristics of both identifiable and anonymous data. Pseudo-anonymized data retains enough information to be useful for analysis while reducing privacy risks compared to directly identified data. However, it's critical to understand that pseudo-anonymized data is still considered personal data under privacy laws like GDPR because re-identification remains possible when combined with the separately stored key or additional information. Therefore, it remains subject to data protection regulations, though certain processing activities may carry reduced risk. The technique is valuable for analytics, research, testing, and data sharing scenarios where direct identification isn't necessary but the ability to link records or occasionally re-identify individuals is needed. Strong security measures must protect the re-identification key.
Applicable Laws & Regulations
- 1GDPR Article 4(5) (Pseudonymization)
- 2GDPR Recital 26 (Identifiable persons)
- 3GDPR Article 32 (Security measures)