Thanks to all who have replied. Some useful discussion as well as many
pointers to the ICO guidance that I should have located first - even if
it is now six years out of date and pre-GDPR.
Best wishes,
Paul
Paul Ticher
22 Stoughton Drive North, Leicester LE5 5UB
0116 273 8191
On 26/03/2019 20:45, Phil Bradshaw wrote:
> At the end of the day you have to make a judgement as to whether an individual is likely to be identifiable taking into account all the means reasonably likely to be used on a case by case basis having regard to purpose & context & controls used. Recital 26.
>
> But data minimization is also relevant.
>
> Recent example. Our estates team wanted to use a processor to do some resource modelling using individual patient episodes from several data sets.
>
> Proposal:
> All data sets pseudonymised using a common pseudo identifier for patients
> Outward postcode plus first digit of inward
> Age
>
> All data would be processed once by a vetted supplier with a GDPR compliant contract (if required), and appropriate due diligence, and be deleted immediately analysis complete
>
> Inquiries revealed the exercise could be done without the common identifier, and outward code only and age in 5 year bands would be acceptable.
>
> Assessment:
> Pseudonymisation unacceptable - not necessary
> Age and postcode suggestion might meet anonymisation requirements in the particular case but would still breach minimisation principle.
>
> Conclusion:
> Contracted with no identifier, age in 5 year bands, and outward code only. Contract in fact met GDPR Art 28 standards but did not strictly need to as we (and DPO) were satisfied that, in context, it could be regarded as effectively anonymised data.
>
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