The problem with this is, the risk of identifiability is not fixed. Even if you redact the postcode as you suggest, it would have a fairly high risk of identification in a rural location (much higher than in an urban location).
https://ico.org.uk/media/1061/anonymisation-code.pdf
Page 30 onwards may help, if you haven't already seen it. Refers to DPA98 but the principle remains. Bear in mind you're talking about health data, and so special category (if it's identifiable).
Ben Heathcote
Information Security Officer (Compliance)
Information Security & Governance Team
IT Service
Newcastle University
NE1 7RU
Telephone: 0191 208 6950
Email: [log in to unmask]
-----Original Message-----
From: This list is for those interested in Data Protection issues [mailto:[log in to unmask]] On Behalf Of Darren Davies
Sent: 03 September 2018 14:58
To: [log in to unmask]
Subject: [data-protection] aggregated data to include a postcode
Hi practitioners
We are being asked for advice on the use of public health data to provide a better service to the clients. In short the legally held data would be aggregated based on location, ethnicity and potential deprivation to assist with getting clients a better health option. I have stated that data protection legislation does not apply to data that has been rendered anonymous when it has been carried out in such a way that the data subjects are no longer identifiable but the service would like the full postcode information. In a circumstance such as
nationality
street name
postcode
outcome of service aggregated to say - needs further support, should be referred to service 'A'
The only part I could see that may amount to personal data would be the postcode, if a French (just picked this at random) man lived in a known street with a known postcode it could be reasonable to identify that man from the data despite no name, date of birth or reference number.
What are your thoughts on this? I am being overly concerned? My advice was to redact the postcode to HA1 1XX etc and this would then not identify the part of the road the person lived in meaning a higher level of re-identification would be needed to remove pseudonymisation (yes I looked up how to spell it!)
Thoughts would be appreciated, my current position is no but sometimes aggregated data can assist in sending services to those who need it most and for many do not know it exists.
Thanks for any support
regards
Darren
DPO - Harrow Council
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