ARTICLE · 29 SEPTEMBER 2025

Personal Data Or Not? CJEU Weighs In On Pseudonymisation In EDPS v. SRB

Goodwin Procter LLP

Explore more from Goodwin Procter LLP

On 4 September 2025, the Court of Justice of the European Union (CJEU) delivered a ruling in EDPS v. SRB (Case C-413/23 P) that clarified how the EU General Data Protection Regulation (GDPR) applies to pseudonymised data.

European UnionPrivacy

Curtis McCluskey

On 4 September 2025, the Court of Justice of the European Union (CJEU) delivered a ruling in EDPS v. SRB (Case C-413/23 P) that clarified how the EU General Data Protection Regulation (GDPR) applies to pseudonymised data. The ruling addressed both the definition of personal data in this context and the responsibility on controllers when transferring personal data to third parties.

The case, brought forward by the European Data Protection Supervisor (EDPS) against Single Resolution Board (SRB), focused on three questions: whether pseudonymised personal opinions qualify as personal data, under what conditions is pseudonymised information treated as personal data, and what are the controller obligations regarding reidentification risks during data processing.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

Related Articles

Ten AI Giants, One Regulator And A Lesson For Everyone Else: What The ICO’s Foundation Model Report Really Tells Us

United KingdomPrivacy

Burges Salmon LLP

Hotel Management Agreements: 10 Key Points For Hotel Owners

United KingdomPrivacy

Private CCTV, Ring Doorbells And Police Investigations: Where Does UK GDPR Draw The Line?

United KingdomPrivacy

Cyber Extortion Has Evolved. It’s No Longer Just About Locked Systems

United KingdomPrivacy

To Fine Or Not To Fine: EDPB Confirms Default Position In GDPR Enforcement Should Be To Fine

Crowell & Moring LLP

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Privacy
- Data Protection

Related Comparative Guides

Comparative Guide

Data Protection & Cybersecurity

See more popular content from

Privacy

Pre-Christmas Update On The ePrivacy Regulation

The General Data Protection Regulation ("GDPR") will enter into force 25 May 2018, and will provide new general data protection standards.

European UnionPrivacy

Reed Smith (Worldwide)

Ten AI Giants, One Regulator And A Lesson For Everyone Else: What The ICO’s Foundation Model Report Really Tells Us

The UK's Information Commissioner's Office has completed its supervision of major AI foundation model developers, revealing significant gaps in data protection practices and setting new expectations for legitimate interests assessments, transparency, and special category data handling. The regulator has now turned its attention to agentic AI systems, warning that autonomy is not an excuse for poor compliance and launching a call for evidence that will shape future regulatory guidance.

United KingdomPrivacy

Burges Salmon LLP

ICO Cookie Crackdown 2.0: The ICO’s New Storage And Access Technologies Guidance

The UK Information Commissioner's Office has finalized its guidance on storage and access technologies, expanding compliance requirements beyond traditional cookies to include tracking pixels, device fingerprinting, and web storage. Organizations must now navigate stricter consent standards and three new narrow exceptions introduced by the Data (Use and Access) Act 2025, while facing significantly increased enforcement penalties of up to £17.5 million or 4% of annual worldwide turnover.

United KingdomPrivacy

Data And Cyber Update - August 2026

Explore comprehensive legal insights and expert commentary across diverse practice areas and industries. Access thought leadership through written articles and podcast discussions that address current legal developments and emerging trends.

United KingdomPrivacy

Stephenson Harwood

What The ICO’s Transformation Into The Information Commission Means For Your Organisation

On 30 September 2026, the Information Commissioner's Office formally becomes the Information Commission. It is the most significant structural change to the UK's data protection regulator in its history, and yet, many organisations are wondering what practical implications this change will have. Here's what you need to know.

United KingdomPrivacy

Is It A Bot? EU AI Act Transparency Rules Take Effect 2 August 2026

From 2 August 2026, the EU AI Act requires businesses to disclose when people are interacting with AI systems, mark synthetic content for detection, label deepfakes, and inform individuals...

United KingdomPrivacy

Travers Smith LLP

Significant Changes To UK Data Protection Legislation – Are You Still Compliant?

The Data (Use and Access) Act 2025 (the DUAA) officially became law in June 2025, with a phased enforcement model under which different provisions take effect at different times.

United KingdomPrivacy

Shepherd and Wedderburn

Privacy Policy 101: What You Need To Know (And How To Stay Compliant)

In the digital age, data privacy is a critical concern for businesses and individuals alike. A key element of any organisation's data protection strategy is its privacy policy.

United KingdomPrivacy

Herrington Carmichael LLP

European Commission Press Release: EU AI Act Transparency Enforcement Starts This Sunday! Do You Know Who Your Chatbots Are? We Break Down The Commission’s Guidelines On Transparency Below

The European Commission has announced that EU AI Act transparency rules take effect August 2, 2026, requiring chatbots to identify themselves, deepfakes to be labeled, and AI-generated content to be marked. Organizations must assess whether their AI systems trigger disclosure, labeling, or content-marking requirements, with limited exceptions and penalties reaching €15 million or 3% of global turnover for noncompliance.

Seyfarth Shaw LLP

ICO Launches Consultation On Draft Guidance Regarding Anonymisation And Pseudonymisation For Research Purposes

The UK's Information Commissioner's Office has opened a public consultation on draft guidance addressing anonymisation and pseudonymisation techniques for processing personal data in research, archiving, and statistical contexts. The guidance explores critical distinctions between anonymous and pseudonymous data, outlines required safeguards under UK GDPR, and examines emerging technologies including synthetic data and privacy-enhancing tools.

United KingdomPrivacy