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Amnesia – High-Accuracy Data Anonymization

amnesia.openaire.eu

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Re: Amnesia – High-Accuracy Data Anonymization

#41

Post by Mary-Jane »

privacylawthrow wrote: post #14

For data to be anonymous under GDPR, it is not enough that individuals cannot be identified from the anonymized data set. If individuals can be identified when the anonymous data set is compared with the source data set, the anonymized data is not "anonymous". For data to be truly anonymous under GDPR. there must be no other additional data that would allow for reidentification. If there is any other data that, when…

Can someone explain the point of this requirement? If a malicious actor has access to the source data there's no need to compare it to anonymized data. What am I missing?

Re: Amnesia – High-Accuracy Data Anonymization

#44

Post by privacylawthrow »

m0nster wrote: post #39
privacylawthrow wrote: post #14

For data to be anonymous under GDPR, it is not enough that individuals cannot be identified from the anonymized data set. If individuals can be identified when the anonymous data set is compared with the source data set, the anonymized data is not "anonymous". For data to be truly anonymous under GDPR. there must be no other additional data that would allow for reidentification. If there is any other data that, when…

In my experience, this is a question of interpretation (see e.g. Recital 26 and the question of what is "reasonably likely"). You can ask ten different experts, and you will get ten different opinions. Unfortunately, many aspects of the GDPR are interpreted very heterogeneously, both in individual countries and by different supervisory authorities within the countries themselves. For this reason, it is essential that…

> In my experience, this is a question of interpretation (see e.g. Recital 26 and the question of what is "reasonably likely").

This is absolutely true. The hard part is that was it "reasonably likely" changes as technology changes. It's entirely possible that a data set that qualifies as anonymous today will not be anonymous in 5 years. Organizations are responsible for the data they publish. If data loses its anonymity in the future due to release of other data sets and/or improved technology, the organization releasing the data will be responsible for the release of personal data, even if it wasn't personal data at the time of release.

Re: Amnesia – High-Accuracy Data Anonymization

#45

Post by user837382991 »

Mary-Jane wrote: post #41
privacylawthrow wrote: post #14

For data to be anonymous under GDPR, it is not enough that individuals cannot be identified from the anonymized data set. If individuals can be identified when the anonymous data set is compared with the source data set, the anonymized data is not "anonymous". For data to be truly anonymous under GDPR. there must be no other additional data that would allow for reidentification. If there is any other data that, when…

Can someone explain the point of this requirement? If a malicious actor has access to the source data there's no need to compare it to anonymized data. What am I missing?

Privacy and security are not the same. Security is to protect against malicious actors. Privacy is to protect data from everyone that’s not the person PII itself.

Re: Amnesia – High-Accuracy Data Anonymization

#47

Post by lmkg »

Mary-Jane wrote: post #41
privacylawthrow wrote: post #14

For data to be anonymous under GDPR, it is not enough that individuals cannot be identified from the anonymized data set. If individuals can be identified when the anonymous data set is compared with the source data set, the anonymized data is not "anonymous". For data to be truly anonymous under GDPR. there must be no other additional data that would allow for reidentification. If there is any other data that, when…

Can someone explain the point of this requirement? If a malicious actor has access to the source data there's no need to compare it to anonymized data. What am I missing?

If someone makes inferences on the de-identified data, or joins it against another dataset. The source dataset lets those inferences or joins be tied back to the original identifying data.

The main point is that de-identified data can still be "personal" so it's regulated. If you share or make public psuedonymous data, that data is still covered by GDPR so you have to inform the individuals, have a legal basis (such as consent), let them opt out (if applicable), etc. Even if it's been pseudonymized, I would want to know if/when my data is sold to a marketing firm or whatever.

Re: Amnesia – High-Accuracy Data Anonymization

#48

Post by MaxBarraclough »

lmkg wrote: post #47
Mary-Jane wrote: post #41

Earlier quoted context omitted.

Can someone explain the point of this requirement? If a malicious actor has access to the source data there's no need to compare it to anonymized data. What am I missing?

If someone makes inferences on the de-identified data, or joins it against another dataset. The source dataset lets those inferences or joins be tied back to the original identifying data. The main point is that de-identified data can still be "personal" so it's regulated. If you share or make public psuedonymous data, that data is still covered by GDPR so you have to inform the individuals, have a legal basis (such…

> The source dataset lets those inferences or joins be tied back to the original identifying data.

But if the attacker lacks the source dataset, they can't do this, and if they possess the source dataset, they'd use it for their analysis rather than using the anonymised dataset.

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