Skip to content

Pseudonymisation

What is Pseudonymisation?

The processing of personal data in such a manner that it can no longer be attributed to a specific data subject without the use of additional information. Unlike anonymisation, pseudonymised data is still considered personal data under GDPR.

Privacy

Each of these is named in at least one of the same controls as pseudonymisation. The number is how many controls name both.

What the standards actually require on pseudonymisation

Requirements naming pseudonymisation across 6 standards, quoted from the control text.

Standard 7 per Section 35 + the Schedule of the Jamaica Data Protection Act 2020: Personal data shall be processed in a manner that ensures appropriate security including protection against unauthorised or unlawful processing + accidental loss + destruction or...

JM-DPA2020-Standard7-Security-Sec35-Appropriate-Technical-Organisational-Confidentiality-Integrity-Availability-Resilience · Jamaica DPA 2020 Standard 7 - Security + Section 35 + Appropriate Technical and Organisational Measures + Confidentiality + Integrity + Availability + Resilience + Encryption + Pseudonymisation + Risk-Based Security →

Particular caution must be exercised in any project processing genetic or biometric data, because such data are unique, can reveal health predispositions, inherited diseases and kinship, affect relatives as well as participants, cannot be changed and remain fo...

edpb-guidelines-1-2026-on-processing-of-personal-data-for-scientific-research-purposes::8.4 · 8.4 Genetic and biometric data: particular caution, restrictive purposes, pseudonymisation, ethical approval, federated storage with secure access, role-based controls, and community information for isolated populations →

Articles 53 and 67: an applicant may seek access only for the Article 53(1) purposes (public or occupational health, policymaking and regulation, official statistics, which three are reserved to public sector bodies; health education;

regulation-on-the-european-health-data-space-ehds::67 · Submit complete access applications with purpose, data, safeguards and pseudonymisation justification →

Pseudonymisation (GDPR Art.4(5)) processes personal data in a way that the data can no longer be attributed to a specific data subject without additional information kept separately and subject to technical and organisational measures.

ENISA-DPE-3.2 · Pseudonymisation →

Both when deciding the means of processing and during processing, the controller must apply appropriate measures to comply with the Decree-Law, including the Article 5 controls; pseudonymisation is named as one such measure.

federal-decree-law-no-45-of-2021-on-the-protection-of-personal-data-uae-pdpl::7(2) · Article 7(2): protection by design, including pseudonymisation →

Articles 39 + 46 of UU PDP establish security + breach notification obligations. Article 39: Personal Data Controller shall protect personal data processed through implementation of appropriate technical + organisational + and physical security measures + comm...

IDPdp-Security-BreachNotification-72Hour-Art39-Art46-Encryption-Pseudonymisation-Records-IR · Indonesia PDP Article 39 + Article 46 + Reasonable Security + Encryption + Pseudonymisation + Personal Data Breach Notification 3x24 Hours (72 Hours) to DPA + Data Subjects + IR Plan + Records →

Questions people ask about pseudonymisation

What is Pseudonymisation?
The processing of personal data in such a manner that it can no longer be attributed to a specific data subject without the use of additional information. Unlike anonymisation, pseudonymised data is still considered personal data under GDPR.
Why is Pseudonymisation important for compliance?
Pseudonymisation is a key concept in Privacy. Understanding pseudonymisation helps organizations meet regulatory requirements, reduce risk, and demonstrate due diligence during audits. Our compliance platform maps 1,016 frameworks with 316K cross-framework control mappings.
Which compliance frameworks address Pseudonymisation?
Pseudonymisation appears in the requirement text of Jamaica Data Protection Act 2020, EDPB Guidelines 1/2026 on processing of personal data for scientific research purposes, Regulation on the European Health Data Space (EHDS), ENISA Data Protection Engineering - From Theory to Practice, Federal Decree-Law No. 45 of 2021 on the Protection of Personal Data (UAE PDPL). Across these standards we have identified 24 controls that name it directly, each linked to the control text on the compliance platform.
Where can I learn more about Pseudonymisation?
Explore our compliance framework pages to see how pseudonymisation applies across different standards and regulations. Our implementation guides provide step-by-step guidance, and the compliance platform offers AI-powered analysis of how this concept maps across 1,016 frameworks.

See how Pseudonymisation applies across compliance frameworks

Our platform maps 1,016 frameworks with 316K cross-framework control mappings. Explore how this concept is addressed across standards.

Written and maintained by Gerard Blokdyk, The Art of Service.