ECJ Clarifies Line Between Pseudonymised and Personal Data

Alex van der Wolk recently spoke to Lexology Pro about a recent Court of Justice of the European Union case that considered whether pseudonymised data is considered personal data under for the purposes of GDPR. The Court found that pseudonymised data constitutes personal data only when third parties have means “reasonably" allowing them to identify data subjects.

About the decision, Alex, commented:

“If the holder of the pseudonymised data does not have the reasonable means to reidentify, the pseudonymised data – for the purpose of GDPR – is anonymous. This is a major confirmation of the scope of pseudonymised data, which runs contrary to the positions held by the European Data Protection Supervisor and European Data Protection Board.”

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