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ARTICLE · 21 FEBRUARY 2022

Pseudonymised Data Is Personal Data – But In Whose Hands? ICO Calls For Views On Third Chapter Of Draft Anonymisation Guidance

Herbert Smith Freehills Kramer LLP
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On 7 February 2022, the Information Commissioner's Office ("ICO") announced the publication of the third chapter of its draft guidance on anonymisation, pseudoymisation and privacy enhancing technologies (the "Draft Guidance").

United KingdomPrivacy
Duc Tran
Duc Tran
Sara Lee
Sara Lee

On 7 February 2022, the Information Commissioner's Office ("ICO") announced the publication of the third chapter of its draft guidance on anonymisation, pseudoymisation and privacy enhancing technologies (the "Draft Guidance"). Following on from the first and second chapters published on 28 May 2021 and 8 October 2021, respectively, which focus on anonymisation, the new third chapter aims to clarify the much debated concept of pseudonymisation.

In addition to our previous blog post on the first chapter of the Draft Guidance, this blog post summarises some of the key concepts in the second and third chapters, focusing on pseudonymisation.

Pseudonymisation in a nutshell

In the context of data protection law, pseudonymisation refers to the process of replacing, removing or transforming data, so that it is unidentifiable without additional information (e.g. replacing names or other identifiers with codes or reference numbers), but re-identifiable to the extent that

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