Personal Data

Identifiers can either be directly tied to an individual’s “identity” or be “pseudonymous,” which means there are appropriate technical and operational processes within the organization using the identifier to keep this identifier separate from an individual’s identity.

If an identifiable identity (e.g., email) goes through an appropriate de-identification process it can become a pseudonymous identifier. Privacy regulations group both directly identifiable identity and pseudonymous identifiers as “personal data,” but state pseudonymous identifiers pose lower privacy risks to people