SaaS Agreements – Data Protection – Anonymising Data

Many SaaS suppliers use personal data, collected on behalf of SaaS customers, in an anonymised form for their own purposes, such as benchmarking. The UK Information Commissioner’s Office (ICO) Anonymisation Code and more recently the Article 29 Working Party’s Opinion on Anonymisation provide guidance on how to check that personal data is actually anonymous.

If you are a SaaS provider using anonymised personal data you should comply with the recommendations in these two guides, to ensure that you are properly anonymising data, otherwise you could be found to be using personal data in breach of the DPA.

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SaaS Agreements – Data Protection – Anonymising Data

Often SaaS suppliers or SaaS customers anonymise personal data for use in statistical or marketing information but are unaware that by using such anonymised data they could be breaching the Data Protection Act 1998 (DPA). The Information Commissioner’s Office (ICO) has recently confirmed that anonymised personal data may be disclosed without the consent of the data subject, provided that the anonymised data when linked with other information will not lead to the identification of an individual.

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