On July 7, 2026, the European Data Protection Board (EDPB) adopted a draft of new guidelines on anonymization (“Guidelines”) 1.
These Guidelines aim to update Opinion 05/2014 of the Article 29 Working Party on anonymization techniques, in order to take into account developments “in the legal, privacy, engineering and technological landscapes”.
These Guidelines first reiterate that data is anonymous if it does not relate to an identified or identifiable natural person and, taking into account the CJEU judgment of September 4, 2025 2, specify that the anonymous nature of data may vary depending on the entity conducting the analysis. The document also emphasizes that information may relate to a natural person if it is linked to that person due to its content, purpose, or effect, and that a person must be considered identified or identifiable when “they can be distinguished from other in a given context using means reasonably likely to be used and in a way that makes it possible to