Compliance with    Pseudonymization under the GDPR

The rapid advancement and widespread adoption of new technologies present a dual challenge: steering their evolution while simultaneously safeguarding the privacy of the individuals who use them. It is in this latter aspect that data protection becomes critically important.

This protection pertains to the careful handling and restriction of any information that can serve as an identifier of a natural person, achieved through a range of technical measures—pseudonymization being one of those specified by the General Data Protection Regulation (GDPR).

Definition of Pseudonymization

Pseudonymization may be defined as the process applied to data records whereby various identifiers (identifying fields) are replaced with pseudonyms (fictitious identifiers), while maintaining the link between the data and the individual in a separate, secure location. Thus, pseudonymized data should not be mistaken for anonymous data.

In practice, this method involves extracting, encrypting, or obscuring a critical “link” in the data chain so that the information can no longer be attributed to a specific individual without additional information. However, this link—an identifier—is preserved separately to allow for potential re-identification if necessary.

According to the GDPR, the outcome of this process results in two distinct data sets:

• The processed data, which cannot be attributed to an individual without further information.
• The additional information, which retains the severed link and enables re-identification of the data subject.

Pseudonymization of Personal Data under the GDPR

In this context, the GDPR defines pseudonymization as the processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information.

This means that, if necessary, pseudonymized data can be re-identified—provided that the supplementary information enabling this process remains entirely inaccessible to unauthorized individuals.

Therefore, with the appropriate key, re-identification is technically possible. For this reason, under the GDPR, pseudonymized data still qualifies as personal data.

How Pseudonymization May Be Used within the GDPR Framework

While the GDPR cites pseudonymization as a valid data protection measure, its implementation must be tailored to the specific circumstances, the technologies used, and the assessed level of risk.

Pseudonymization may involve techniques such as encryption using a secret key, whereby identifying fields are converted into codes, rendering the data unintelligible. Only those with access to the decryption key can retrieve the original private data.

The GDPR pseudonymization method can be effectively employed in various fields, such as:

• Scientific or medical research, where statistical data must be processed without connecting it to names, addresses, or other personal identifiers.
• Customer databases or marketing research, where a customer’s name can be replaced with a code to protect their identity.

It is crucial that pseudonymization practices be automated. Due to the inherent complexity of data management, standardizing such procedures is essential to ensure both GDPR compliance and the long-term viability of the organization.

Anonymization vs. Pseudonymization

As stated in the GDPR, both anonymization and pseudonymization offer privacy safeguards through data processing. However, they differ significantly in terms of reversibility, data linkage, the nature of the resulting data, and how each is governed by the GDPR.

• Regarding data linkage:
• Anonymization involves the complete and irreversible disassociation of the data from the individual. Once anonymized, the identity of the data subject cannot be recovered.
• Pseudonymization, by contrast, retains the ability to re-establish the link between data and identity through the use of separately stored additional information.

• Regarding the type of data generated:
• Anonymization produces anonymous data, which is no longer considered personal data under the GDPR.
• Pseudonymized data, however, remains indirectly identifiable, since it is possible to reconnect the identity through access to specific keys.

• Regarding GDPR regulation:
• Anonymized data falls outside the scope of the GDPR, as it does not contain personal information.
• Pseudonymized data remains regulated by the GDPR, as it still qualifies as personal data due to the possibility of re-identification.

Choose a Trusted Partner for GDPR-Compliant Pseudonymization

mplementing effective pseudonymization technology when processing data allows organizations to preserve the intrinsic value of such information while simultaneously facilitating compliance with the GDPR.

Given the vast volumes of data flowing through various departments of an organization today, it is imperative to partner with a provider that offers customized and automated data protection solutions through pseudonymization.

Collaborating with a trusted company experienced in GDPR-compliant pseudonymization and anonymization is the most reliable way to mitigate the risk of data breaches and ensure the confidentiality of sensitive information.

At Pangeanic, we offer robust solutions based on the GDPR pseudonymization framework, ensuring data reliability, integrity, and confidentiality through advanced technologies that secure the entire data processing cycle.