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Privacy & Data

CDT Position Paper on The Treatment of Pseudonymous Data Under The Proposed Data Protection Regulation

In recent months, the debate around the proposed European Data Protection Regulation has increasingly focused on whether the law should afford special treatment to pseudonymous data. CDT has previously argued that the Regulation should be formulated to incentivize companies to keep data in less readily-identifiable forms, and different treatment of pseudonymous data does make sense in certain cases. At the same time, we believe that the definition and rules for the processing of “pseudonymous data” must be carefully constrained so that this exception does not swallow the rule that citizens have a right to the protection of their personal — including pseudonymous — data.

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