Pseudonymisation Clause Examples

Pseudonymisation. As far as possible, the data will be processed in such a way that it can no longer be assigned to a natural person without the use of additional information. The collection of IP addresses is avoided in system administration and any recorded IP addresses are made anonymous via shortening. Possibility of anonymisation / pseudonymisation by the client

Pseudonymisation. Every processing operation is to be assessed as to whether its purpose can also be realised without direct personal reference. If this is the case, the processing of personal data is to be performed in a manner such that these data can no longer be associated to a specific data subject without reference to additional information. This additional information is to be stored separately and is itself subject to technical and organisational measures intended to ensure that the personal data cannot be associated to an identified or identifiable natural person.

Pseudonymisation. Measures to process personal data in a manner to ensure that the personal data can no longer be assigned to a specific data subject without reference to additional information if this addi- tional information is separately preserved and is subject to technical and organisational measures.

Pseudonymisation. Protection of personal data The TolaData application does not require the entering of personal data other than upon registration and login. With the Terms of Use, TolaData and customer agree that customer alone is the controller of all (personal) data that customer processes through the Software. Data entered by clients can only be accessed in the software by users as assigned by the client’s organisation and permissions for the data of each project are set and managed by the client’s Admin users. Ownership and legal responsibility for such data is always with the client. While TolaData cannot control (and thus be held liable) whether a client enters or uploads a file including personal information, we encourage best practices and pseudonymisation for personal data and can provide advice and recommendations in regards to managing personal data based on the specific data, tracking and reporting requirements of each client or project.

Pseudonymisation. If the Personal Data is used for evaluation purposes which can also be fulfilled with pseudonymised data, then pseudonymisation techniques will be used. For each data field, it will be pre-defined whether pseudonymisation needs to be used or not, in order to avoid it being traced back to a particular person. The pseudonymisation key will be stored in a data safe, in order to restrict access as far as possible.

Pseudonymisation. Pseudonymisation is not currently applied. The application of pseudonymisation procedures is the responsibility of the client.

Pseudonymisation. Aliaxis Deutschland GmbH observes the principle of data minimisation. If there is no specific purpose for processing a personal data record, the data record is pseudonymised.

Pseudonymisation. Assessments must be pseudonymised if the personal reference to the result is not absolutely neces- sary.

Pseudonymisation. Pseudonymisation means processing personal data in such a way that the data can no longer be attributed to a specific data-subject without the use of additional information, (e.g. a dataset linking trial identifiers to identified or identifiable persons) provided that such additional information is kept separately and under controlled access, to prevent the data being identifiable in isolation. Though theoretically such information could be used to match against a clinical trial dataset and identify individuals, this would be very difficult in practice and could only occur if there was a major breach of security. Sharing of pseudonymous data is recommended and should be the normal expectation. Clinical trial data is pseudonymous when collected, or can be easily turned into pseudonymous data within the research unit, by processing of the data set and splitting off the identifying data points. It would be rare for trial data to become fully anonymised, or at least not until many years have elapsed after data collection. There are legal obligations on sponsors to maintain the pseudonymised dataset, as collected, for many years, the exact time depending on national regulations. In addition, the original investigators, or their institution, may want to use the pseudonymising key in case they wish to return to the same participants to carry out further investigations (assuming they have the ethical approval and / or explicit consent to do so). The advantage of sharing pseudonymised data is that, if the secondary user discovers good reasons for clarifying, expanding or matching some of the data, or even for further investigations with some of the source population, they can contact the holders of the pseudonymous data and discuss if and how this might be achieved, because the individual participants are still (indirectly) identifiable. This does not mean that identifiable or identifying information would be transferred to a secondary user, unless there was explicit consent from the participant for this to happen (though this seems unlikely to be given). It only means that if a case can be made for identifying the individuals in the data set it is at least possible to discuss the possibilities of doing this, including possibly returning to the individuals concerned to request additional consent.