Cybersecurity Policy Report, Slovenia Clarifies Difference Between Data Pseudonymization, Anonymization, (Jun 17, 2026)
An opinion from the Slovenian Information Commissioner clarifies that pseudonymization isn’t the same as anonymization of personal data because pseudonymized data can still be linked to an identifiable individual.
The opinion follows a request for clarification of the differences in pseudonymization and anonymization in connection with an amendment to the Animal Protection Act designed to protect personal data of pet owners.
Slovenia collects data on animals and their owners for “supervision procedures, official procedures and also as part of broader investigations into suspected organized illegal dog trafficking or other criminal acts related to animal protection, including suspicions of animal torture,” the information commissioner noted. After a set period, the data is scheduled for anonymization.
In certain contexts, it was believed that “a more appropriate solution would be pseudonymization of data, in which the direct identifiers of the individual are no longer visible or accessible without additional information and protective measures” while still providing the ability to establish a connection between individual records, the commissioner said.
The commissioner explained that pseudonymization means the processing of personal data in such a way that personal data cannot be attributed to a specific individual without additional information, while anonymization is usually based on the use of specific methods and techniques that depersonalize data.
The European Union’s General Data Protection Regulation (GDPR) clearly distinguishes between the concepts of anonymization and pseudonymization, the commissioner said, and pseudonymization would not satisfy the legal requirement for data anonymization in the animal protection law.
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