Article 30a – Application of pseudonymisation and identification of a natural person

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.

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.

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.

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.

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.

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.

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.

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.

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.

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.