ICO anonymisation guidance: the anonymising step is processing and needs a lawful basis (Information Commissioner's Office, Anonymisation guidance, 'Introduction to anonymisation', 28 March 2025 (under review after the Data (Use and Access) Act))
The UK regulator says the anonymising step needs a lawful basis and a stated purpose, but is likely to be fair and lawful. A UK holder should record that step and mention it in its notice.
Dated 18 Oct 2026Source checked 18 Oct 2026Basis: primary text
In the source's own words
“This means that you must comply with data protection requirements for your anonymisation process. This includes ensuring you have a lawful basis for it and you clearly define your purpose(s) and provide people with information about it. In general it is likely that applying anonymisation techniques to the personal data you hold will be fair and lawful.”
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