Set by the law · GDPR recital 26

Pseudonymised data

In plain English

Data that have been pseudonymised. They stay personal data for anyone who can re-link them to a person with additional information; the Court of Justice held in 2025 this is not automatically so for everyone.

The official text

Personal data which have undergone pseudonymisation, which could be attributed to a natural person by the use of additional information should be considered to be information on an identifiable natural person.

Regulation (EU) 2016/679 (GDPR), recital 26EUR-LexRead it on Fino →

‘pseudonymisation’ means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

Regulation (EU) 2016/679 (GDPR), Article 4(5)EUR-LexRead it on Fino →

pseudonymised data must not be regarded as constituting, in all cases and for every person, personal data for the purposes of the application of Regulation 2018/1725, in so far as pseudonymisation may, depending on the circumstances of the case, effectively prevent persons other than the controller from identifying the data subject in such a way that, for them, the data subject is not or is no longer identifiable

Court of Justice of the EU, judgment of 4 September 2025, EDPS v SRB, C-413/23 P, paragraph 86EUR-Lex

Related

The official text is quoted word for word from the English version of the source named under it; only the version published in the Official Journal of the EU is legally binding. The plain-English line is Fino’s own summary, not legal advice.