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ARTICLE · 13 SEPTEMBER 2026

Unique Identifiers: The POPIA Issue That Can Derail Data Commercialisation Or Monetisation

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South African organisations pursuing data monetisation initiatives face a critical regulatory requirement under POPIA that many overlook: using unique identifiers to link datasets across entities may require prior authorisation from the Information Regulator. This legal blind spot affects customer-360 programmes, AI initiatives, data enrichment projects, and commercial partnerships where identifiers like ID numbers or customer references are used to match information between responsible parties.

South AfricaMedia, Telecoms, IT, Entertainment
Ridwaan Boda
Ridwaan Boda
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Many organisations are looking for ways to monetise or commercialise the data they already hold. This may include enriching customer profiles, combining datasets, creating new analytics products, building customer insights, supporting AI models or collaborating with third parties. Under the South African Protection of Personal Information Act (“POPIA”), a legal blind spot that many organisations miss when seeking to monetise or commercialise data is that the use of unique identifiers may require prior authorisation from the Information Regulator.

A unique identifier is defined under POPIA as “any identifier that is assigned to a data subject and is used by a responsible party for the purposes of the operations of that responsible party and that uniquely identifies that data subject in relation to that responsible party.” This is not the most helpful of definitions but for practical purposes this can include information such as an ID number, customer number, account number, employee

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