Abstract

Anonymization or de-identification techniques are methods for protecting the privacy of human subjects in sensitive data sets while preserving the utility of those data sets. In the case of health data, anonymization techniques may be used to remove or mask patient identities while allowing the health data content to be used by the medical and pharmaceutical research community. The efficacy of anonymization methods has come under repeated attacks and several researchers have shown that anonymized data can be re-identified to reveal the identity of the data subjects via approaches such as “linking.” Nevertheless, even given these deficiencies, many government privacy policies depend on anonymization techniques as the primary approach to preserving privacy. In this report, we survey the anonymization landscape and consider the range of anonymization approaches that can be used to de-identify data containing personally identifiable information. We then review several notable government privacy policies that leverage anonymization. In particular, we review the European Union’s General Data Protection Regulation (GDPR) and show that it takes a more goal-oriented approach to data privacy. It defines data privacy in terms of desired outcome (i.e., as a defense against risk of personal data disclosure), and is agnostic to the actual method of privacy preservation. And GDPR goes further to frame its privacy preservation regulations relative to the state of the art, the cost of implementation, the incurred risks, and the context of data processing. This has potential implications for the GDPR’s robustness to future technological innovations – very much in contrast to privacy regulations that depend explicitly on more definite technical specifications.

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