Article 25a – Application of pseudonymisation and identification of a natural person
Also numbered 25aITRE–LIBE amendment 1159 (CJ72-AM-791073, pages 84–89) proposes a different Article 25a, ‘Privacy Enhancing Technologies’. The tracker keeps it as a separate provision: Article 25a (new).
Changes since2 October 2026ST 13886/26
Keeps the wording of the Council text of 2 October 2026. Every change, paragraph by paragraph
Text as printed
New provision · Same wording since 2 October · Changes since the Commission proposal
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 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.
The Board shall issue an opinion, in accordance with Article 64(2) of this Regulation, addressing the application of pseudonymisation and anonymisation, including related technical and organisational measures.
The Chair of the Board shall request the opinion referred to in paragraph 4 no later than 6 months after the entry into force of this Regulation. The opinion shall be reviewed and updated where necessary.
Cross-referenceParagraph 7 cites ‘the opinion referred to in paragraph 4’. Paragraph 4 mentions no opinion. Paragraph 6 provides for it.