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Table of contents

• What does the Guidance cover?
• Key concepts of anonymisation and pseudonymisation
• Identifiability and identifiability risk management
• Anonymisation and Pseudonymisation techniques and approaches
• Accountability and governance (primarily within the context of DPIAs)
• Examples of use in practice by way of case studies and accompanying glossary
• What’s different from previous draft guidance?
• How does the ICO’s approach measure up against others’?
• Key takeaways

Article summary

Information Law analysis: On 28 March 2025 the UK Information Commissioner’s Office (ICO) published its guidance on anonymisation and pseudonymisation under the UK GDPR (the Guidance). A long time coming, with drafts and sector-specific guidance published intermittently since 2021, the Guidance offers a practical response to addressing key concerns around compliant use of pseudonymised and anonymised data, especially in the context of data sharing, advanced analytics and modern technologies available to the ‘motivated intruder’. Written by Alex Jameson & Steph Ong of Bird & Bird