Germany: BfDI issues position paper on anonymisation under GDPR
The Federal Commissioner for Data Protection and Freedom of Information ('BfDI') issued, on 29 June 2020, a position paper ('the Position Paper') on anonymisation under the General Data Protection Regulation (Regulation (EU) 2016/679) ('GDPR'). In particular, the BfDI highlighted that the GDPR only contains limited provisions on anonymisation despite its high practical importance, and therefore, the BfDI had organised a public consultation process on the matter including stakeholders from the economic and scientific sector as well as from public authorities and civil society.
Furthermore, the BfDI held that its most important finding is that the anonymisation of personal data is possible with a corresponding legal basis, highlight the telecommunications sector as an example. In addition, the BfDI found that the obligation to delete personal data immediately can be fulfilled through anonymisation, if a stricter standard is applied.