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Protecting GDPR Personal Data with Pseudonymization

In the context of GDPR, part of securing Personal Data means employing multiple levels of protection to ensure that data is not lost, destroyed, or disclosed to unauthorized individuals. One GDPR principle for securing Personal Data is Pseudonymization, which is defined as “…the processing of personal data in such a way that the data can no longer be attributed to a specific Data Subject without the use of additional information.”

Beyond the fact that the GDPR lists pseudonymization amongst appropriate technical and organisational measures designed to implement data-protection principles [Article 25, Recital 1], and we can bet that auditors will be looking to see if it has been implemented, there are two practical benefits of using pseudonymized Personal Data:

  • Allows organizations to continue to use many existing operations and processes that might otherwise be impossible to perform if the Personal Data was simply deleted, and
  • Reduces the cost to appropriately protect the data, versus if the Personal Data were left intact.

Additionally, pseudonymization allows for the ultimate reassociation of the Personal Data with the individual when required by authorized individuals, or as part of a data subject’s exercise of their rights under GDPR, such as the right to erasure.