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T-557/20 Single Resolution Board v EDPB: On the Interpretation of Identifiability

Shweta Reddy Degalahal


Keywords: identifiability, pseudonymised data, personal data

Case T-557/20 Single Resolution Board v European Data Protection Supervisor (ECLI:EU:T:2023:219)
Based on existing case law, the General Court provides guidance on the examination of the concept of identifiability for the definition of personal data under Article 3(1) of Regulation 2018/17251. The Court has provided clarity with respect to determining the possibility of re-identification of pseudonymised data that has been transferred to a third party with no access to the code key. The possibility of re-identification has to be determined from the perspective of the party that doesn’t have the code key and to whom the data has been transferred to by the data controller.

Shweta Reddy Degalahal is a PhD Researcher at Tilburg Institute of Law, Technology and Society. For correspondence: <>.


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