Run a realistic reidentification test: What evidence should | AIGP
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Run a realistic reidentification test: What evidence should resolve whether the data are anonymized?

AIGP Understanding How Laws, Standards and Frameworks Apply to AI Hard

A retained key and vendor linkage mean pseudonymization may remain; realistic reidentification evidence is decisive.

The question

An EU employer subject to the GDPR uses an employee-assistance model. Names are replaced with codes, but HR retains the reidentification key and the vendor can link outputs to employee cases. What evidence should resolve whether the data are anonymized?

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  1. Obtain the vendor's statement that names were removed.
    Removing direct identifiers does not establish anonymization when another party can link records or retain reidentification capability.
  2. Review encryption records for the coded files.
    Encryption addresses security but does not determine whether individuals remain identifiable through the key or available information.
  3. Classify the coded records as anonymous in an internal policy.
    An internal classification cannot override the factual ability of HR or the vendor to identify employees.
  4. Run a realistic reidentification test. ✓
    A realistic reidentification test helps determine whether available information, the retained key, and vendor linkage leave employees identifiable.
The trap
Retained keys and linkage capability require a realistic identifiability analysis; removing names alone is insufficient.

How to remember it

A retained key and vendor linkage mean pseudonymization may remain; realistic reidentification evidence is decisive.

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Part of the Certsqill AIGP question bank · Understanding How Laws, Standards and Frameworks Apply to AI · Every answer, right and wrong, comes with its own explanation.