Can pseudonymised personal data ever become anonymous data in the hands of a Third Party?
27 July 2026
2 Comments
The question in the heading arises from the DSG v ICO (Court of Appeal) and SBS v EDPS (CJEU) legal sagas (see references). There is confusion as to whether or not pseudonomysed personal data, in the hands of a Third Party, can be treated as anonymous data, when that Third Party does not have any access to any details that could identify any data subject. Some researchers, for instance, are of the view that, as such data is always outside
