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CS Professional · Artificial Intelligence, Data Analytics and Cyber Security - Laws and Practice · Data Analytics

A company wishes to share customer data with an analytics vendor after removing names and phone numbers, but keeps a separate key table that can re-link records to individuals. How should this data be treated?

It is pseudonymised data and still counts as personal data. Since a key table can re-link records to individuals, re-identification remains possible, so it is not truly anonymised and privacy obligations continue to apply.

  1. APseudonymised data, which can still identify individuals and remains personal dataCorrect
  2. BFully anonymised data outside any privacy obligation
  3. CPublic domain data open to any use
  4. DNon-personal data because direct identifiers were removed

Explanation

Because a key table allows re-identification, the data is only pseudonymised. Anonymisation requires that re-identification is not reasonably possible. Therefore privacy obligations continue to apply to the shared dataset.

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