Interactive Advertising Bureau - IAB: presented a critical report on the EDPB Guidelines 1/2025 on pseudonymization.

The Interactive Advertising Bureau (IAB) Spain announced that, together with IAB Europe, Alliance Digitale (France), IAB Italy, IAB Poland, IAB Sweden, Association for Internet Development in the Czech Republic (SPIR) and VIA Nederland (collectively the IAB Associations) has submitted a report containing strong criticisms of  the EDPB Guidelines 1/2025 on pseudonymization.

The position paper outlines several concerns of IAB Associations, including the fact that the Guidelines overinterpret the notion of personal data, resulting in significant practical burdens for data controllers attempting to implement effective pseudonymization in line with the principles of the General Data Protection Regulation (GDPR).

Another criticism concerns the imposition of absolute criteria for the effectiveness of pseudonymization, which bring this process closer to the more rigorous anonymization process, in a way that is inconsistent with the provisions of the GDPR (of which, according to the IAB Associations, the EDPB would also provide an incorrect interpretation as to the application of Article 11).

In light of these concerns, the IAB Associations propose some recommendations to the EDPB:

• issue consolidated guidelines that include guidelines on both pseudonymization techniques and anonymization techniques (updating the old Opinion 5/2014);
• withdraw the current Guidelines to avoid legal uncertainty and a potential conflict with the GDPR;
• ensure that the guidelines on pseudonymisation are consistent and in line with the current case law of the CJEU;
• Provide guidance on how to develop new technologies:
• provide more actionable examples.