Article 29 Working Party Opinion 05/2014: removing direct identifiers is not enough (Article 29 Working Party, Opinion 05/2014 on Anonymisation Techniques (WP216), adopted 10 April 2014, section 2.2.2)
The test is singling out, linking and inference, not just the removal of names. Free text in tickets and chats can still identify a person through context, so name-scrubbing alone will not make a lot anonymous.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“An effective anonymisation solution prevents all parties from singling out an individual in a dataset, from linking two records within a dataset (or between two separate datasets) and from inferring any information in such dataset. Generally speaking, therefore, removing directly identifying elements in itself is not enough to ensure that identification of the data subject is no longer possible.”
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