On 28 September 2022, the International Federation of Pharmaceutical Manufacturers and Associations (IFPMA) and European Federation of Pharmaceutical Industries and Associations (EFPIA) published joint guidelines concerning the use of social media and digital media channels by pharmaceutical companies (Joint Digital Guidelines).  IFPMA  and EFPIA are umbrella trade bodies for

This post was originally published on our sister blog Inside Privacy

On April 10, 2014, the Article 29 Working Party adopted an Opinion on anonymization techniques.  The Working Party accepts that anonymization techniques can help individuals and society reap the benefits of “open data” initiatives – initiatives intended to make various types of data more freely available – while mitigating the privacy risks of such initiatives.  Yet, the standard for anonymization proposed by the Working Party is not an easy one to meet, and the Working Party reiterates its belief that data will remain regulated personal data in the event a party – not necessarily the recipient of the data – is capable of associating it with a living individual.

The Working Party starts by pointing out that rendering personal data anonymous is a data processing operation in itself.  As a result, data controllers can only engage in such activity if the raw data concerned has been collected in compliance with applicable data protection laws.  In addition, based on existing data minimization obligations, data controllers should treat the application of anonymization techniques to data as a form of “further use”, compatible with the original use only if the anonymization technique is reliable.
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