Pseudonymization: excellent confidentiality technique
What is pseudonymization?
Pseudonymization is defined in Article 4.5 of the General Data Protection Regulation(GDPR) as:
“the processing of personal data in such a way that they can no longer be attributed to a data subject without the use of additional information, provided that such additional information is listed separately and is subject to technical and organizational measures designed to ensure that the personal data are not attributed to an identified or identifiable natural person.”
Pseudonymization involves the processing of personal data, so all security measures must be complied with in accordance with the Data Protection Regulations, which are mandatory for any company or professional.
Pseudonymization guarantees
Pseudonymization and therefore pseudonymized data have the following guarantees:
— The impossibility of identifying the person concerned without the use of additional information.
— Comply with the principles of the RGPD, especially those related to limits to processing (purpose, conservation and transfer of data).
— Guarantees according to the risk involved in the treatment.
— Technical and organizational safeguards to prevent security breaches
What is pseudonymization for?
Pseudonymization serves to reduce the risk of loss of confidentiality in the processing of personal data of data subjects (patients, clients, students, partners, etc.) and helps companies and professionals to meet their data protection obligations(RGPD+ LOPD).
It is important to note that the company or professional using pseudonymization may reverse the process and recover the original personal data.
Pseudonymization techniques
The most common pseudonymization techniques are as follows:
Encryption with secret key
A type of encryption in which the holder of the decryption key can reverse the process at any time.
Deterministic encryption or hash function with key erase key
It generates a random number as a pseudonym for each attribute in the database and subsequently deletes the matching table.
Decomposition into tokens
Replaces card ID numbers with values that are of little use to those who want to fraudulently access personal data
Hash function
Hashes or hash functions are algorithms that manage to create from an input (be it a text, a password or a file, for example) an alphanumeric output of normally fixed length that represents a summary of all the information given to it (i.e., from the input data it creates a string that can only be recreated with the same data).
Function with stored key
It is a type of hash function that makes use of a secret key as a supplementary input value (the execution of the function could be reproduced with the attribute and the secret key).
Usual areas of application of pseudonymization
The areas in which this type of technique is usually applied for the processing of personal data are Cloud Computing (cloud services) and Big Data (large-scale data).
Although these are not the only areas where this technique is applied, pseudonymization will be possible in internal or external complaint processes, as well as in any area where it is relevant to guarantee the anonymity of the person.
How does this differ from anonymization?
Anonymization is a set of data that does not relate to an identified or identifiable natural person. In other words, personal data becomes impersonal.
The most important difference with pseudonymization is that anonymization is not governed by the provisions of the GDPR, but must comply with the rest of the rules in force in the legal system.
And why does the GDPR not apply to this type of processing?
Because in this type of processing there is no material possibility of associating the anonymized data to a specific natural person, directly or indirectly, either through the use of other data sets, information or technical and material measures that may be available to third parties.
When is data considered to be anonymized?
When the costs, possibilities of identifying the individual in the dataset, or the technological means to reverse anonymization have been evaluated.
In anonymization, the original personal data is destroyed and cannot be recovered later, so it must be considered an irreversible technique for data processing.
Pseudonymization and Internal Whistleblower Channels
The Internal Whistleblower Channels are those tools that the company makes available to its employees to report infractions committed within the organization. Among others, they are mandatory for companies with 50 or more employees.
An important aspect for the good use and obtaining of results from the internal reporting channels, is that the company establishes procedures that guarantee the confidentiality of the identification data of the complainant or any third party that is related to the complaint, being that the pseudonymization technique could be a good solution to address this aspect, as established in Article 16 of the European DIRECTIVE 2019/1937 of the European Parliament and of the Council of 23 October 2019 on the protection of persons who report breaches of Union law.
The fact that it is not possible to identify the complainant a priori is directly linked to the principle of prohibition of retaliation, established in Article 19 of the aforementioned Directive, both in terms of threats and attempted retaliation.
Business Adapter® at your service
If you are a client and think that a pseudonymization system would be interesting for your business, contact your consultant to receive documentation and instructions.
If you are not yet a client and want us to help you comply with the European and Spanish data protection regulations(RGPD + LOPD) to which any company or professional is obliged, call us at 96 131 88 04, contact us by email: info@businessadapter.es, or leave your message in this form:
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