In short
Rendering personal data incapable of being associated with an identified or identifiable natural person, even when matched with other data; anonymous data is no longer personal data.
Anonymisation means rendering personal data incapable of being associated in any way with an identified or identifiable natural person, even when matched with other data. Anonymous data is no longer personal data and falls outside the KVKK. Article 7 of the KVKK provides anonymisation as a method of disposal alongside erasure and destruction of data whose processing grounds have ceased.
Anonymisation Methods
The Personal Data Protection Authority’s guidance on erasure, destruction and anonymisation lists various methods:
- Methods that do not distort values: Removing variables, removing records, regional suppression and top or bottom coding.
- Methods that distort values: Micro-aggregation, data swapping and adding noise.
- Statistical methods: Techniques such as aggregation and k-anonymity that make each record indistinguishable from a certain number of others.
Re-identification Risk
Whether a dataset is anonymous is assessed not only by looking at that dataset but also considering the possibility of combining it with other sources. The average salary of a small department or a regional statistic on a rare disease may reveal individuals even without names. Anonymisation should be treated as a process in which this risk is regularly reassessed.
Difference from Pseudonymisation
Pseudonymisation, where names are replaced with codes and individuals can be re-identified with a key, is not anonymisation; pseudonymised data remains personal data.
Frequently Asked Questions
Is a dataset anonymous once names are removed?
Often not. Keeping data such as date of birth, postcode and gender together may allow re-identification. To be anonymous, the data must not be linkable to any person by reasonable means.
Can anonymised data be transferred abroad?
Truly anonymous data is not personal data, so the KVKK's transfer rules do not apply. However, it should be documented that anonymity was achieved and re-identification risk assessed.
Related Services
Guides
Publications in this area
- Rights Over a Person’s Image and Photograph 15.10.2024
- Can the Corporate E-mail Histories of Employees Who Leave Their Jobs Be Made Available to Another Employee? – An Evaluation in the Context of the Law on the Protection of Personal Data 06.05.2024
- Deepfake Technology – Legal Challenges and Key Questions 17.11.2023
- Push Notifications in Turkish Law: Legal Obligations and User Rights 25.10.2023
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