Article 29 Working Party Releases Opinion On Anonymisation Techniques

Author:Ms Kate Brimsted, Katalina Chin and Tom C. Evans
Profession:Reed Smith

In April, the EU's Article 29 Working Party (Working Party) adopted an opinion on Anonymisation Techniques (Opinion). The Opinion is designed to provide guidance for organisations on the use of common anonymisation techniques, and the risks that can be presented by them. When data is truly anonymised – so that the original data subject cannot be identified – it falls outside of EU data protection law. The Opinion notes that the re-use of data can be beneficial, providing "clear benefits for society, individuals and organisations". However, achieving true anonymisation is not easy, and can diminish the usefulness of the data in some circumstances. The EU regime does not prescribe any particular technique that should be used to anonymise personal data. To guide organisations in designing their own policy on anonymisation, the Opinion examines the two principle forms: (a) randomization and (b) generalization. In particular, the Opinion looks at the relative strengths and weaknesses of each technique, and the common mistakes and failures that arise in relation to them. Each technique is analysed using three risk criteria, which include: 1. The risk that data identifying an individual could be singled out 2. The 'linkability' of two records that relate to an individual 3. Inferences that can be drawn about one set of data based on a second set of data The Working Party stated that by considering these strengths and weaknesses, organisations will be able to take a risk-based approach to the anonymisation technique used...

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