Anonymization

Definition

The process of permanently and irreversibly removing identifying information from data so that individuals cannot be identified directly or indirectly. True anonymization goes beyond simply removing names or obvious identifiers—it requires consideration of indirect identifiers, combination risks, and future re-identification possibilities. Techniques include aggregation, generalization, noise addition, and data suppression. The critical distinction: anonymization must be irreversible. If there's any way to reverse the process or re-identify individuals (even theoretically), the data is pseudonymized, not anonymized. Successfully anonymized data is no longer considered personal data under GDPR and similar laws, exempting it from privacy regulations. However, regulators are skeptical of anonymization claims due to the risk of re-identification. Proper anonymization requires expertise, ongoing review, and documentation of the techniques used and their effectiveness.

Applicable Laws & Regulations

  1. 1GDPR Recital 26 - Anonymous information not subject to data protection principles
  2. 2GDPR Article 89(1) - Anonymization for research purposes
  3. 3CCPA Section 1798.145(a)(5) - Deidentified information requirements

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