Data Protection

Anonymisation

Process rendering data no longer identifiable to individuals.

How the laws define this

All three instruments agree that anonymisation involves processing or transforming personal data so that individuals can no longer be identified, thereby allowing the data to be used, published, or reused without standard personal data protections. They diverge, however, on the strictness of the technical threshold and the primary purpose of the operation. The PDPL Implementing Regulations set an absolute technical standard, requiring an irreversible process where re-identification is impossible by any reasonable means, which formally strips the data of its status as personal data. Conversely, the Data Governance Guide for Media Practice in Kenya draft presents anonymisation as a risk-mitigation technique involving identifier removal or aggregation to prepare data for wider use, explicitly distinguishing it from pseudonymisation. Meanwhile, the Act on Open Data and Re-use of Public Sector Information treats anonymisation primarily as a procedural prerequisite for dataset publication, ensuring public sector data can be lawfully reused in compliance with the GDPR and national data-protection obligations.

Synthesised from the 3 statutory definitions below. Each one is quoted in full, with its source.

How jurisdictions differ

What is distinctive in each definition, binding law in force first. Showing 2 of the 3 instruments that define this term; all are listed under Definitions below.

JurisdictionInstrumentStatusWhat is distinctive
PolandAct of 11 August 2021 on Open Data and Re-use of Public Sector InformationIn ForceRequires anonymisation for legal publication and reuse of datasets containing personal data to comply with GDPR and national data-protection obligations.
KenyaData Governance Guide for Media Practice in Kenya (Media Council of Kenya draft)DraftDescribes as a risk-mitigation technique distinct from pseudonymisation.

What it triggers

  • Polish public sector entities must anonymise datasets containing personal data to enable legal publication and reuse.source
  • The Draft recommends anonymisation as a risk-mitigation technique.source

Definitions (3)

A risk-mitigation technique defined as processing that removes or aggregates identifiers so individuals are no longer identifiable, making data safe for wider use or publication without personal data protections; presented as distinct from pseudonymisation.

A technical process that irreversibly de‑identifies personal data such that re‑identification is impossible; data rendered anonymous under this regulation are no longer considered personal data for the purposes of the PDPL. The Implementing Regulations require that anonymisation be irreversible and that re‑identification cannot be achieved by any reasonable means.

The process of transforming personal data so that individuals cannot be identified from the published dataset; required where personal data are present to enable lawful publication and reuse while ensuring compliance with the GDPR and national data‑protection obligations.

Not to be confused with

Pseudonymisation

Anonymisation removes identifiability without additional information, unlike pseudonymisation which requires it.

Questions and answers

What is anonymisation under Polish law?

Anonymisation transforms personal data so individuals cannot be identified, enabling legal publication and reuse in compliance with GDPR and national data-protection obligations.

How does anonymisation differ from pseudonymisation?

Anonymisation removes identifiers so data is no longer attributable to individuals, unlike pseudonymisation which leaves data re-identifiable with additional information.

Is anonymisation required for publishing datasets?

Yes, Polish law requires anonymisation where personal data are present to enable legal publication and reuse.