On February 10, 2020, Germany’s Federal Commissioner for Data Protection and Freedom of Information (BfDI) launched its first public consultation procedure. The consultation invites comments on a position paper of the BfDI which addresses the anonymization of personal data under the General Data Protection Regulation (GDPR), with a particular focus on the telecommunications sector (for … Continue Reading
On November 4, 2019, the Spanish Supervisory Authority (“AEPD”), in collaboration with the European Data Protection Supervisor, published guidance on the use of hashing techniques for pseudonymization and anonymization purposes. In particular, the guidance analyses what factors increase the probability of re-identifying hashed messages. The AEPD explains that the probability of re-identification increases if more … Continue Reading