EDPB Guidelines 01/2025 on Pseudonymisation (version for public consultation) (EDPB Guidelines 01/2025, adopted 16 January 2025, executive summary)
The EDPB's view, adopted before EDPS v SRB, is that pseudonymised data stays personal even when the key is held by someone else. Supervisory authorities may still apply this cautious view.
Dated 17 Oct 2026Source checked 17 Oct 2026Basis: primary text
In the source's own words
“Pseudonymised data, which could be attributed to a natural person by the use of additional information, is to be considered information on an identifiable natural person ... This statement also holds true if pseudonymised data and additional information are not in the hands of the same person.”
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