Pseudonymous data

1 The original European Union (‘EU’) Commission’s January 2012 draft of the EU General Data Protection Regulation (‘GDPR’) did not refer to pseudonymous data nor to pseudonymization. Introduced for the first time by the rapporteur for the EU Parliament’s Civil Liberties, Justice and Home Affairs (LIBE) Committee in December 2012, pseudonymization has triggered vivid discussions during the negotiation of the GDPR. Some Member States, such as Germany, were in favour of introducing a lightweight regime for controllers of pseudonymous data. While such a regime was...