Texts to 22 Oct 2026

EUDPR· Article 30a

Analysis in our dossiers
The definition of “personal data”

Text

Article 30a EUDPR as printed in the Council text of 22 October 2026

Application of pseudonymisation and identification of a natural person

Source Council, 22 October 2026. Article 30a: ST 14756/26, page 152 · pp. 152–153 · exact text page

Article 30a

30a - Application of pseudonymisation and identification of a natural person (1) Controllers and processors may apply pseudonymisation in order to reduce the risks to the data subjects concerned and to comply with their obligations under this Regulation, in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information. The application of pseudonymisation shall be subject to appropriate technical and organisational measures, including security measures, to prevent other persons from identifying the data subject.

(2)

Pseudonymised data shall not be considered personal data for a third party if that third party is unable to identify the natural person to whom the data relates.

(3)

Where a third party discloses, transmits or otherwise makes data referred to in paragraph 2 available to another third party and, in light of all relevant circumstances, that other third party possesses or can obtain means reasonably likely to enable the data subject to be identified, both the transmission of the data to that other third party and the subsequent processing of the data by that other third party is processing of personal data.

(4)

Where a processor processes personal data on behalf of a controller, that data shall be considered personal data for the processor, and the processor continues to be subject to the obligations applicable under this Regulation.

(5)

To determine whether a natural person is identifiable, including through personal data having undergone pseudonymisation, account shall be taken of all the means reasonably likely to be used to identify the natural person directly or indirectly.

(6)

The European Data Protection Board shall issue an opinion, in accordance with Article 64(2) of the Regulation (EU) 2016/679, addressing the application of pseudonymisation and anonymisation, including the related technical and organisational measures.

Article 30a(1)

(1)

Controllers and processors may apply pseudonymisation in order to reduce the risks to the data subjects concerned and to comply with their obligations under this Regulation, in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information. The application of pseudonymisation shall be subject to appropriate technical and organisational measures, including security measures, to prevent other persons from identifying the data subject.

Article 30a(2)

(2)

Pseudonymised data shall not be considered personal data for a third party if that third party is unable to identify the natural person to whom the data relates.

Article 30a(3)

(3)

Where a third party discloses, transmits or otherwise makes data referred to in paragraph 2 available to another third party and, in light of all relevant circumstances, that other third party possesses or can obtain means reasonably likely to enable the data subject to be identified, both the transmission of the data to that other third party and the subsequent processing of the data by that other third party is processing of personal data.

Article 30a(4)

(4)

Where a processor processes personal data on behalf of a controller, that data shall be considered personal data for the processor, and the processor continues to be subject to the obligations applicable under this Regulation.

Article 30a(5)

(5)

To determine whether a natural person is identifiable, including through personal data having undergone pseudonymisation, account shall be taken of all the means reasonably likely to be used to identify the natural person directly or indirectly.

Article 30a(6)

(6)

The European Data Protection Board shall issue an opinion, in accordance with Article 64(2) of the Regulation (EU) 2016/679, addressing the application of pseudonymisation and anonymisation, including the related technical and organisational measures.

Article 30a in the whole EUDPR

How the provision changed

Show the statuses

Each text against the law in forceEach text against the text before it

What each text would do to the law in force
Element Council18 Jun 2026Art 30a Council3 Sep 2026Art 30a Council2 Oct 2026Art 30a Council22 Oct 2026Art 30a
Compared withlaw in force18 Jun text3 Sep text2 Oct text
Permission to pseudonymise
30a(1), first sentence Adds Added
30a(1) Adds Unchanged
30a(1), first sentence Adds Unchanged
30a(1), first sentence Adds Unchanged
Identifiability test
30a(1), second sentence Adds Added
30a(3) Adds, changed since 18 Jun Changed
30a(5) Adds, changed since 3 Sep Changed
30a(5) Adds Unchanged
Pseudonymised data in the hands of others
30a(2) Adds Added
30a(2) Adds, changed since 18 Jun Changed
30a(2) Adds, changed since 3 Sep Changed
30a(2) Adds Unchanged
Without-prejudice clause
30a(3), first sentence Adds Added
Not in the law in force or this text, dropped since 18 Jun Dropped
Not in the law in force or this text In neither text
Not in the law in force or this text In neither text
Processors
30a(3), second sentence Adds Added
30a(4) Adds, changed since 18 Jun Changed
30a(4) Adds, changed since 3 Sep Changed
30a(4) Adds Unchanged
Onward disclosure to someone able to identify
Not in the law in force or this text In neither text
30a(5) Adds, added since 18 Jun Added
30a(3) Adds, changed since 3 Sep Changed
30a(3) Adds Unchanged
EDPB opinion on pseudonymisation and anonymisation
30a(4) Adds Added
30a(6) Adds, changed since 18 Jun Changed
Not in the law in force or this text, dropped since 3 Sep Dropped
30a(6) Adds Unchanged
Measures preventing identification
Not in the law in force or this text In neither text
Not in the law in force or this text In neither text
30a(1), second sentence Adds, added since 3 Sep Added
30a(1), second sentence Adds Unchanged

Each text against the law in force: +Adds adds a provision the law in force lacks— neither the law in force nor the text has it changed from the text before

Each text against the text before it: +Added in this text, not in the text before~Changed wording changed−Dropped drops a provision the text before added=Unchanged same as the text before— in neither text