Anonymous Data
Definition
Information that cannot be linked back to an identifiable individual by any reasonable means. True anonymous data is not personal data and therefore falls outside most privacy regulations. However, achieving genuine anonymity is challenging—data that seems anonymous can often be re-identified by combining it with other datasets or applying advanced analytics. For data to be truly anonymous, it must be impossible for anyone (including you) to re-identify individuals, even with additional information or future technology. This is a high bar. Many organizations mistakenly believe they have anonymous data when they actually have pseudonymized or deidentified data, which still counts as personal data under laws like GDPR. True anonymization is irreversible and doesn't allow for re-identification under any circumstances. If there's any reasonable possibility of re-identification, the data remains personal data subject to privacy laws.
Applicable Laws & Regulations
- 1GDPR Recital 26 - Anonymous information
- 2GDPR Article 4(1) - Definition excluding information that is not personal data
- 3CCPA Section 1798.145(a)(5) - Exclusion for deidentified or aggregate information