The Czech Data Protection Association (Spolek pro ochranu osobních údajů), a founding member of EFDPO, has submitted its comments on the European Data Protection Board’s (EDPB) draft Guidelines 01/2025 on Pseudonymisation.
In its response, the association welcomes the EDPB’s efforts to provide clarity on this important topic but raises concerns regarding the broad interpretation of personal data. The comments emphasize the importance of considering the relative concept of identifiability, as established in case law, and warn against overly broad definitions that may create unrealistic expectations for controllers and processors.
Furthermore, the association suggests refining specific aspects of the guidelines, including the classification of lookup tables, the necessity of certain pseudonymisation measures, and the implications for international data transfers. The response also calls for more practical examples to clarify common misconceptions about pseudonymised data.
EFDPO supports the discussion on practical and legally sound approaches to pseudonymisation and welcomes ongoing dialogue on the topic.