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Does GDPR require anonymization of user idents when used in testing and development?

User idents will identify an employee by other employees because it's linked to login system. Outside of the company they may only hint to which employee if a list of employees is available. The usage is purely auditing, who created and edited data.

Where does this stand within GDPR regulations? Do you need consent from an employee for such ? "Can your work be visible to other employees?". I would think consent is implicit just by working there?

User idents

By user idents I mean such as windows login name, LDAP short names such as "PDIG". These identify the operator making data edits and they appear in almost every database table/row with typical column names such as created_by, modified_by, similar to how files are stamped in a filesystem. In my recent anonymization jobs I find that this represents about half the processing time and often appear in primary and unique indexes, thus creating challenges with data constraints in the anonymization programs.

Why do this?

I currently have gone through a lot of anonymization work at current client, some of which is complicated because of database constraints and relations.

** Yes they are indeed person-identifying data, but they just identify an employee internal to the company and are never sensitive. Do one have to hide the fact that people worked there?

I have the feeling that this is ok with GDPR, but since it is somewhat unclear we have currently ended up anonymizing it anyhow.

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    You have a legitimate interest to maintain audit logs of access and modification of files, so you don't need to anonymise these sorts of things. – user4210 Jul 8 '19 at 8:16
  • yes, but these logs are generally not available to testers and developers. – Per Digre Jul 8 '19 at 8:37
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    So? They are available to admin staff, and will be useful when you need to track down breaches or people accessing stuff they shouldn't have been accessing. I wouldn't be touching that sort of information, it's legitimate. – user4210 Jul 8 '19 at 8:50
  • Could you explain a bit more clearly what kind of data set you have and why you need to anonymize or pseudonymize it? – amon Jul 8 '19 at 18:08
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    There is no question here. "Give me a reason not to [likely a legal obligation]" is not on-topic here. – Nij Jul 9 '19 at 23:38
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Anonymization is used when you don't need the personal data anymore, but maybe you still want to keep some aggregated data (statistics, etc.). Anonymized data cannot be linked to a real person anymore, so it's not considered personal data the GDPR doesn't care about it. Example of anonymized data: 23.5% of users on your site are from the UK. That's all you know and all you store, and there's no way to find a list of those people.

Pseudonymization is used when you want to store the data more securely, by making it harder for unauthorized people to link it to a real person. Example of pseudonymized data: the user with user ID 12345 bought a new HP laptop this month. Who is user 12345? It is possible to link that number to a name, but not everybody can do it. Maybe only the sales office knows (maybe stored in an excel file), but the developers won't find that info in any database table (the databases only store the IDs).

I'm not sure what you need in your specific case. It depends on whether you need to be able to link that data to real people, and whether you really need to restrict that ability. If the amount of data is small, if it is not sensitive at all, if it's kind of hard to link it to other personal data anyway, if the cost of implementing a better solution is too high compared to the value of the personal data, etc. then it might not be worth trying to pseudonymize it, for example. And if you don't really need that data after all, you might think of deleting it or keeping it in an anonymized format (aggregate statistics).

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