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Anonymization unfortunately is completely broken under GDPR. In principle it providesa clean path for personal data to become usable outside of the restrictions
by oezi 11mo ago
Anonymization unfortunately is completely broken under GDPR. In principle it providesa clean path for personal data to become usable outside of the restrictions of GDPR, but in practice it turns out to be impossible based on current definitions.
The key issue is that anonymization under GDPR requires that a link to a real person can never be re-established even considering the person doing the anonymization. Consider a clincial study on 100 patients and their some diagnostic parameter such as creatinine or H1bc which was legally collected using consent and everything. Lets assume we would like to share only the 100 values of the diagnostic without any personal data. It would seem quite anonymous, but GDPR would put a simple test if anybody using reasonable efforts could re-establish an identity. And sure the original researcher can because s/he has a master file containing the mapping. So the data isn't anonymous and actually can never be anonymous.
- buzer 11mo agoYou should probably look into pseudononymization in your case, not actual anonymization. Look into C‑413/23 P in more detail to see if it's applicable in your situation, it's essentially the first case law around it. You probably do need some extra controls (like contract that the data is not shared) just in case to avoid the data coming in hands of someone else who could identify the people depending on how detailed the data is.