Article 29 Working Party Opinion 05/2014: anonymising is itself a further processing (Article 29 Working Party, Opinion 05/2014 on Anonymisation Techniques (WP216), adopted 10 April 2014, executive summary)
De-identifying a dataset is itself processing that needs a lawful basis and must be compatible with the original purpose. A holder should record that step too, even though it usually passes easily.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“Anonymisation constitutes a further processing of personal data; as such, it must satisfy the requirement of compatibility by having regard to the legal grounds and circumstances of the further processing.”
Where it was read
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