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Processing personal data for statistics, even though the personal identifiers are removed, is still considered a personal data processing operation and it falls under GDPR, if the state is a member of EEA or if the affected data subjects are on EEA territory. However, the publishing of de-identified personal data is not considered processing of personal data, unless the data can be used to identify a data subject. The key to understanding this is the definition of “personal data” in article 4 GDPR: “any information relating to an identified or identifiable natural person (‘data subject’)”. So if the information published by a state leads to the identification of a natural person – either by another person or by an algorithm – that information is considered personal data.
You can find more details at this link:
- Article 4 GDPR – Definitions: https://advisera.com/gdpr/definitions/
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Feb 02, 2022