Cybersecurity Policy Report, Trade Groups Weigh in on EU Pseudonymization Initiative, (Nov 19, 2025)

By Tony Foley

Several European Union trade organizations, led by digital marketing and advertising association IAB Europe, have penned a letter to Ana Talus, chair of the European Data Protection Board (EDPB), discussing their views on the EDPB’s initiative to organize a stakeholder event on anonymization and pseudonymization following a ruling on the issue by the Court of Justice of the EU (CJEU).

The event was planned after the September release of the CJEU’s decision in EDPS v. SRB (case C-413/23). In that ruling, the CJEU agreed with the finding of a lower court that that pseudonymized data shouldn’t be regarded, in all cases and for every person, as personal data for purposes of the application of the EU’s General Data Protection Regulation (GDPR) (CPR, Oct. 14).

According to an IAB Europe press release, the letter notes that the CJEU’s clarification that pseudonymized data may, in certain circumstances, qualify as anonymous data “creates an important opportunity to advance the objectives of the EU Data Strategy and strengthen Europe’s capacity to develop and deploy innovative technologies across all sectors of the economy.” Specifically, the letter calls on the EDPB to ensure a participatory event format, with active involvement of EDPB members, balanced representation from public and private stakeholders, and the presentation of concrete use cases to demonstrate how anonymization and pseudonymization work in practice.

The letter emphasized the importance of developing practical and operational frameworks for anonymization and pseudonymization to provide companies with legal certainty, including checklists, interpretive grids and other tools. In addition, it encouraged consideration of the role of certification schemes in the discussion. The signatories to the letter pledged to contribute their expertise to the upcoming stakeholder event and to support the EDPB’s ongoing work.

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