PDPC Selected Topics guidelines (revised 23 May 2024): data is anonymised only if there is no serious possibility of re-identification (PDPC, Advisory Guidelines on the PDPA for Selected Topics (revised 23 May 2024), Chapter 3, paras. 3.4 and 3.5)
Anonymised data is outside the PDPA, but the PDPC's test is a serious-possibility-of-re-identification test that looks at the data combined with other information the recipient has or is likely to have, plus the safeguards in place. Removing names alone (de-identification) is not enough.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Data would not be considered anonymised if there is a serious possibility that an individual could be reidentified, taking into consideration both:”
Figures it counts in
It is shown on its own, not counted into a figure.
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