UK GDPR and DPA 2018: Anonymisation, Pseudonymisation and Privacy‑Enhancing Technologies—Legal Tests, ICO Guidance and Practical Techniques

Published by a LexisNexis Information Law expert

Practice notes

This Practice Note examines the law and practice in relation to anonymisation, pseudonymisation and privacy enhancing technologies (or PETs).

It specifically outlines what constitutes robust anonymisation and pseudonymisation and sets out core methods that can be applied. It further introduces the suite of tools referred to as PETs. It assesses the framework under the United Kingdom General Data Protection Regulation, Assimilated Regulation (EU) 2016/679 (UK GDPR), alongside the UK Data Protection Act 2018 (DPA 2018). Where pertinent to the UK GDPR, EU case law and guidance are taken into account. For information on the position under the EU’s General Data Protection Regulation, Regulation (EU) 2016/679 (EU GDPR), see Practice Note: in the EU. On this topic, key differences exist between the UK GDPR regime and the EU GDPR. That said, at a high level the UK GDPR and EU GDPR remain closely aligned. For background on the UK GDPR and how it relates to the EU GDPR, see Practice Note: The UK General Data Protection Regulation (UK GDPR)—Summary of key legislation...

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Heather Catchpole

Bird & Bird

Heather is an associate in Bird & Bird’s London-based Privacy & Data Protection team and advises on a broad range of data protection and ePrivacy questions faced by businesses.Heather advises on marketing rules, cookies, DPIAs, and the implementation of innovative technologies, and has experience drafting data protection provisions in commercial contracts and advising on data protection risks in an M&A context. Heather has worked with businesses in a range of sectors including sport, media & entertainment, video gaming, and retail & consumer.Heather has a particular interest in Adtech, children’s privacy, and the intersection between UI design and data protection law. She also enjoys advising on the interaction between data protection and the new digital legislation we are seeing in the EU and UK such as the DMA, DSA, and Online Safety Bill.Prior to joining Bird & Bird Heather spent four years in the IP/IT and data...

Alex Jameson

Bird & Bird

I am a senior associate in Bird & Bird’s Privacy and Data Protection Group, based in London. I work with UK and international clients across a variety of sectors on a wide range of data protection and e-privacy issues.My experience covers all aspects of information law: from the GDPR, to ePrivacy and Freedom of Information. I enjoy finding practical solutions to difficult questions: be that building a data protection compliance programme within a difficult culture, advising on grey spaces like on-device processing and biometrics, or just finding a calm way to manage stressful moments such as security incidents.I work with all kinds of organisations, but have a particular interest in matters involving AI and new technologies.Separately, I have particular experience working on HR data and employment-adjacent privacy matters.Before joining Bird & Bird, I spent over six years at another private practice firm where I...

Web page updated on 22/05/2026

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