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GDPR specifically mentions pseudonymous data in Recital 26: "The principles of data protection should apply to any information concerning an identified or iden

GDPR specifically mentions pseudonymous data in Recital 26: "The principles of data protection should apply to any information concerning an identified or identifiable natural person. Personal data which have undergone pseudonymisation, which could be attributed to a natural person by the use of additional information should be considered to be information on an identifiable natural person. 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." Under EU law, there is no special class of "personally identifying information". Any data that relates to a person or could be related to a person is protected. It isn't enough to just strip the name and SSN field out of the database and call it anonymous, you need to demonstrate that the data couldn't be attributed to anyone through any reasonably practical process. https://gdpr-info.eu/recitals/no-26/ https://gdpr-info.eu/recitals/no-26/

c0pium 3y ago
That is almost verbatim the definition of PII from Wikipedia and from OMB Memorandum M-07-1616 (the US government definition of PII).
oezi 3y ago
The crucial piece is your link is: > 4To 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. This has been interpreted that any objectively possible way to de-anonymize is reasonable. In particular, considering that all the data of the organization doing the anonymization can be used to try to de-anonymize.
- kwillets 3y ago
  I think they're trying to keep cryptographically secure data out of scope.
bertil 3y ago
That broad definition opens itself to so much… Even raw movie rating data was famously partially de-anonymized. I’m not sure that I could imagine a detailed database with personal activity at a reasonable scale that couldn’t be de-anonymized, at least partly, if one assumes that people use related services and that one has access to them via public social media, mostly. - Emails: of course; - social media: easy; - search queries: LOL; - transport: through commute; - any cultural good: you can connect to contemporary commentary; - fashion shopping: pretty much trivial with OOTD posts; - medial record: not everyone, but most major diagnostics could be matched to social media for many people; - https blobs via VNP: most people would connect to the same four sites again and again, but exact timestamps and public statements on social media; - grocery shopping: harder, but doable as you’d have neighborhood from the store address and a lot of surface… Is the letter of that law against pseudonymous databases?
- genewitch 3y ago
  Is it funny that it is so broad? People don't want their information leaked! Why is this so hard to understand? It makes your job harder? Tough shit. It makes law enforcement tougher to do? Ohhhh nooo, they might have to work for a living instead of pushing buttons. Stop trying to defend companies that do this in service of capital. It is heinous. Some, if not most of us, want to be left alone and not have our addresses and medical history and YouTube stats available for the whole world. There is no such thing as an anonymous dataset. It has been proven again, and again.
  - bertil 3y ago
    No need to be snarky or insulting: I was trying to ask for a sincere assessment of that law. > do this in service of capital Sir, this is ycombinator.com If the intent is that no database with an individual-level breakdown falls under GDPR IID protections, I presume that far more processes and declarations would have to be applied to circumstances where there never was an intent or a credible option to de-anonymize them. This is not how it is enforced, understood, or applied today. The large companies that you criticize so readily would have an issue automating the paperwork or building hashing solutions that divert the problem, but their privacy-respecting competitors would fall under a lot more paperwork and legal risk than they could handle. Thankfully, there are solutions: a lot of people are now handling internal data processes with the same open-source tool, dbt. That platform could help change standards if they knew current patterns do not respect the letter of the law. But their lawyers seem to think otherwise.

c0pium 3y ago

That is almost verbatim the definition of PII from Wikipedia and from OMB Memorandum M-07-1616 (the US government definition of PII).

oezi 3y ago

The crucial piece is your link is: > 4To 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. This has been interpreted that any objectively possible way to de-anonymize is reasonable. In particular, considering that all the data of the organization doing the anonymization can be used to try to de-anonymize.

kwillets 3y ago
I think they're trying to keep cryptographically secure data out of scope.

bertil 3y ago

That broad definition opens itself to so much… Even raw movie rating data was famously partially de-anonymized. I’m not sure that I could imagine a detailed database with personal activity at a reasonable scale that couldn’t be de-anonymized, at least partly, if one assumes that people use related services and that one has access to them via public social media, mostly. - Emails: of course; - social media: easy; - search queries: LOL; - transport: through commute; - any cultural good: you can connect to contemporary commentary; - fashion shopping: pretty much trivial with OOTD posts; - medial record: not everyone, but most major diagnostics could be matched to social media for many people; - https blobs via VNP: most people would connect to the same four sites again and again, but exact timestamps and public statements on social media; - grocery shopping: harder, but doable as you’d have neighborhood from the store address and a lot of surface… Is the letter of that law against pseudonymous databases?

genewitch 3y ago
Is it funny that it is so broad? People don't want their information leaked! Why is this so hard to understand? It makes your job harder? Tough shit. It makes law enforcement tougher to do? Ohhhh nooo, they might have to work for a living instead of pushing buttons. Stop trying to defend companies that do this in service of capital. It is heinous. Some, if not most of us, want to be left alone and not have our addresses and medical history and YouTube stats available for the whole world. There is no such thing as an anonymous dataset. It has been proven again, and again.
- bertil 3y ago
  No need to be snarky or insulting: I was trying to ask for a sincere assessment of that law. > do this in service of capital Sir, this is ycombinator.com If the intent is that no database with an individual-level breakdown falls under GDPR IID protections, I presume that far more processes and declarations would have to be applied to circumstances where there never was an intent or a credible option to de-anonymize them. This is not how it is enforced, understood, or applied today. The large companies that you criticize so readily would have an issue automating the paperwork or building hashing solutions that divert the problem, but their privacy-respecting competitors would fall under a lot more paperwork and legal risk than they could handle. Thankfully, there are solutions: a lot of people are now handling internal data processes with the same open-source tool, dbt. That platform could help change standards if they knew current patterns do not respect the letter of the law. But their lawyers seem to think otherwise.