May 11, 2021

Volume XI, Number 131

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May 11, 2021

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May 10, 2021

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Tomato, To-Ma-Toe: Is CCPA Deidentification the Same Thing As GDPR Anonymization?

Deidentified information is defined within the CCPA to refer to information that “cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer” provided that a business that uses deidentified information takes four operational and organizational steps to ensure that such information is not reidentified or disseminated.[1]

The standard for “deidentification” under the CCPA differs from the standard for “anonymization” under the European GDPR. While the CCPA considers information that cannot “reasonably” identify an individual as deidentified, the Article 29 Working Party interpreted European privacy laws as requiring that data has been “irreversibly prevent[ed]” from being used to identify an individual.[2]


[1] Cal. Civ. Code § 1798.140(h) (West 2020).

[2] Opinion of the Data Protection Working Party on Anonymisation Techniques, 0829/14/EN WP 216, at 7 (adopted April 10, 2014).

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©2021 Greenberg Traurig, LLP. All rights reserved. National Law Review, Volume XI, Number 99
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About this Author

David A. Zetoony Privacy Attorney Greenberg Traurig
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David Zetoony, Co-Chair of the firm's U.S. Data, Privacy and Cybersecurity Practice, focuses on helping businesses navigate data privacy and cyber security laws from a practical standpoint. David has helped hundreds of companies establish and maintain ongoing privacy and security programs, and he has defended corporate privacy and security practices in investigations initiated by the Federal Trade Commission, and other data privacy and security regulatory agencies around the world, as well as in class action litigation. 

David receives regular recognitions from clients and peers for...

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