ICO anonymisation guidance: the same information can be personal data for one party and anonymous for another (Information Commissioner's Office, Anonymisation guidance, 'How do we ensure anonymisation is effective?', 28 March 2025 (under review after the Data (Use and Access) Act))
The ICO takes the same recipient-by-recipient view as the Court of Justice in EDPS v SRB. A UK holder that keeps the originals still holds personal data, while a de-identified lot can be anonymous in the buyer's hands if the buyer cannot reasonably identify anyone.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“the same information may be: personal data in your hands. For example, if you also hold additional information that means people are identifiable (even if you hold this separately and apply technical and organisational controls to it); but anonymous in the hands of other parties. For example, a specific recipient (or the general public), if they have no access to the additional information and no means reasonably likely to be used to obtain it or identify the people by other means.”
Where it was read
Also read from the same source
- ICO anonymisation guidance: the motivated intruder test (Information Commissioner's Office, Anonymisation guidance, 'How do we ensure anonymisation is effective?', 28 March 2025)
- Details that identify together are coarsened and measured
- A person reads records picked at random
- An independent provider tests and certifies before each transfer
Figures it counts in
It is shown on its own, not counted into a figure.
Cited in this guide