RE: Deidentification (ISSUE-188)

I’d like to propose a definition of de-identification which is closer to the concept of anonymization defined in the Article 29 Opinion (


A data-set is de-identified when it is no longer possible to: 

- isolate some or all records which correspond to a device in the dataset,

- link, at least, two records concerning the same device,

- deduce, with significant probability, the value of an attribute from the values of a set of other attributes.


The third criteria may -- in some cases -- go beyond de-identification but the first two are, in my opinion, required to limit re-identification risks.


Best regards,


Vincent Toubiana



De : Justin Brookman [] 
Envoyé : mercredi 16 juillet 2014 04:47
À : (
Objet : Deidentification (ISSUE-188)


All, I have updated the wiki ( to reflect what I *think* are the active change proposals on data minimization.  If I incorrectly culled yours --- or you wish to propose different language --- please let us know!

Received on Thursday, 17 July 2014 13:46:07 UTC