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Data Protection Leader
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Volume: 14 Issue: 9
(September 2017)

Uruguay: URCDP issues guide on de-identification criteria

The Uruguayan data protection authority (‘URCDP’) issued, on 18 September 2017, an updated guide on de-identification (‘the Guide’), in conjunction with the Digital Government and Information Society Agency. The Guide provides key definitions under Uruguayan law of concepts such as de-identification, anonymisation, re-identification and pseudonymisation; and an overview of the stages in the process of anonymising data, outlining how data controllers should design their anonymisation projects and the techniques they can use.

Martin Pesce Cutri, Senior Associate at Ferrere, said, “The URCDP is a very active body and is [known for] the adoption of up-to-date criteria on data protection, seeking to provide answers or guidelines for the most varied issues and challenges that the development of current technology poses to privacy. The Guide is a good step to begin establishing criteria and laying the foundations for the de-identification and anonymisation of personal data for the public and the private sectors that increasingly use these techniques in the generation of statistical and analytic products.”

The Guide advises defining a contingency plan during the first stage of the anonymisation process and that agile response mechanisms to safeguard the identity of the data subject be implemented. The Guide also examines the risks associated with data anonymisation.

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