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by seanhunter
2485 days ago
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The time of validity and how hard it might be to build a profile are not factors in whether or not this is legal under GDPR. Here's the actual text from GDPR on pseudonyms and synthetic keys of this type[1] > The principles of data protection should apply to any information concerning an identified or identifiable natural person. Personal data which have undergone pseudonymisation, which could be attributed to a natural person by the use of additional information should be considered to be information on an identifiable natural person So PII that has been pseudonymized (mapped to a gid in this case) is protected in exactly the same way as if it had not been if the pseudonymized data could be mapped to a natural person by the use of additional data. The pseudonym (gid) is itself also considered PII under gdpr.
[1] https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CEL... |
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I know of multiple systems that use a UID but throw away a user’s information, including the UID mapping, when the user leaves. This allows historic metrics to be retained without ever identifying a user who isn’t still using the system.
AFAICT, guids are a grey area.