On Anonymous and Pseudonymous Data

24 Mar, 2025

If the personal data is rendered anonymous in such a manner that the data subject is not or no longer identifiable, it is not considered personal data and thus outside the scope of the DPA (“The salary of the usual C-Suite banking officers in Spain ranges from 1 million euros to 2 million euros annually.”)

Pseudonymous data on the other hand is a result of processing the personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately. Pseudonymous data is still considered as personal data. (“Mr. A- (not his true name), one of the C-Suite officers of BBB bank, has a salary of 1,500,000 euros.”)

Aggregated data may (i.e., not automatic) likely to result in nonpersonal data.