The ICO Data Sharing Code of Practice which was published earlier this year aimed to provide organisations with practical guidance for data sharing in compliance with data protection law, which we previously wrote about here.

The ICO are aware that data sharing encompasses many other dimensions and thus that the guidance would be updated on an on-going basis. As part of this, the ICO outlined its plans to update its guidance on anonymisation and pseudonymisation and on exploring privacy enhancing technologies. The refreshed guidance will assist in some of the challenges that organisations may face such as determining whether data is personal data or anonymous information and providing appropriate controls that should be adopted.

The key topics to be covered are:

  • Anonymisation and the legal and governance issues in its application;
  • Identifiability, including guidance on managing re-identification risk and concepts such as ‘reasonably likely’ and ‘motivated intruder’ tests;
  • Pseudonymisation techniques and practices;
  • Anonymisation and pseudonymisation requirements for accountability and governance, including data protection by design and data protection impact assessments;
  • Anonymisation and pseudonymisation in research contexts;
  • Guidance on privacy enhancing technologies;
  • Technological solutions and best practices for implementation; and
  • Data sharing options and case study examples to support organisations to choose the right data sharing measures.


The formal guidance will follow in the coming months as the ICO look to gather feedback and insight from key stakeholders, industry members and academics to best understand practical challenges and how to update the guidance accordingly. The ICO will release the guidance chapter by chapter. Once the guidance has been released, the ICO will welcome feedback and contributions in advance of their main public consultation. You can engage with the ICO by adding your input on the initial work by emailing

 Keep an eye on our blog for further updates!