Records / De-identification rules
An independent provider tests and certifies before each transfer
Before a buyer receives anything, a de-identification provider you choose (not the buyer, and not us) tests the copy as an attacker would, with the web, AI assistants and linkage to other data, and certifies it before each transfer, counting the people it found. Health data also needs an expert determination.
Dated 5 Oct 2026Source checked 15 Oct 2026Page out of reach at the last check, 16 Oct 2026Basis: our standard
“The Deidentification Agent shall perform and document quality-control testing reasonably designed to assess whether individuals may remain identifiable through direct identifiers, indirect identifiers, free-text content, unique characteristics, record linkage, or other means.”
In re Spirit Aviation Holdings, Consumer Privacy Ombudsman supplemental report, Dkt. 1684, checked 5 Oct 2026
In re Spirit Aviation Holdings, Dkt. 1684, checked 5 Oct 2026
UK ICO, Anonymisation guidance (motivated intruder test), checked 28 Mar 2025
Everything read from this source (5)Archived copy, 7 Sep 2026
EDPB draft Guidelines 02/2026 on Anonymisation, para 34, checked 7 Jul 2026
Everything read from this source (4)Archived copy, 2 Oct 2026
- The Spirit enterprise data on sale to Google derives from about 190 million flights and touches the personal data of about 97 million passengers; after the 5 October 2026 narrowing the structured passenger systems are out and corporate email stays in, de-identified by Tonic.ai.
- Settle the employee-data question before going to market
- Certified de-identification is the closing condition, so payment waits for it
- Drop consumer transaction systems to clear privacy review; the price held
- In a privacy-sensitive sale, structure beats a higher late price
- In re Spirit Aviation Holdings: Consumer Privacy Ombudsman supplemental report on the sale of deidentified data (conclusion) (In re Spirit Aviation Holdings, Inc., No. 25-11897-SHL (Bankr. S.D.N.Y.), Dkt. 1684 (5 October 2026))
It is shown on its own, not counted into a figure.
Cited in these 2 guides