Datasets:
GDPR Anonymisation & Pseudonymisation Report
Dataset: EU-Retail-UX-Feedback-Live
Regulation: EU General Data Protection Regulation (Regulation (EU) 2016/679)
Review date: 2026-08-13
Owner: UX Data Engineering — EU Retail (UK / FR / DE branches)
This report documents the measures applied so that the published dataset complies with GDPR principles of data minimisation, purpose limitation, and data protection by design and by default (Art. 25), and follows guidance on pseudonymisation (Art. 4(5), Recital 26 & 28).
1. Source systems and collected raw attributes
Raw records arrive in near real-time from three collection surfaces:
- E-commerce website (web analytics + feedback widget)
- Mobile application (iOS/Android in-app feedback)
- Customer service platform (chat/e-mail/ticket summaries)
The raw (pre-processing) records contain the following fields:
| Field | Category | Published? |
|---|---|---|
user_id |
Direct identifier | ❌ Dropped |
user_email |
Direct identifier / PII | ❌ Dropped |
user_name |
Direct identifier / PII | ❌ Dropped |
phone_number |
Direct identifier / PII | ❌ Dropped |
address |
Direct identifier / PII | ❌ Dropped |
session_id_raw |
Indirect identifier | ⚠️ Pseudonymised → session_id |
feedback_text |
Free text | ⚠️ Scrubbed (PII patterns redacted) |
market_region, country_code, language, timestamp, experience_dimension, rating, device_type, source_channel |
Analytical attributes | ✅ Published as-is |
2. Measures applied
2.1 Deletion of direct identifiers (data minimisation)
The fields user_email, user_name, phone_number and address are deleted
from every record before upload. They are never written to the Hub repository.
The raw data remains only in a restricted, access-controlled internal store with a
short retention period, and is deleted on request (right to erasure, Art. 17).
2.2 Pseudonymisation of identifiers (Art. 4(5))
Real user and session identifiers are replaced by pseudonymous IDs computed as:
pseudo_id = HMAC-SHA256(salt, namespace + ":" + raw_id)[0:16]
- The salt is a high-entropy secret stored in a separate secrets manager, accessible only to the data-engineering platform (no human access by default).
- Because the salt is never published, the mapping
pseudo_id → raw_idcannot be reconstructed from the Hub data alone. - The same raw user always maps to the same pseudonymous
user_pseudo_idwithin a salt epoch, enabling longitudinal analysis without re-identification. - A salt rotation policy (e.g. quarterly) further reduces re-identification risk across time windows.
2.3 Free-text scrubbing
The feedback_text field is scanned and residual PII patterns are redacted to
[REDACTED] before publication:
- E-mail addresses (regex for RFC-5322-like patterns)
- Phone numbers (international + local formats, incl. +44/+33/+49)
- UK postcodes, French postcodes (5 digits), German postcodes (5 digits)
- Credit-card-like number sequences
2.4 Data minimisation of published attributes
Only attributes required for UX analytics are published. No financial, health, biometric, political, religious or other special-category data (Art. 9) is collected or published.
3. Validation performed before upload
| Check | Result |
|---|---|
Direct PII columns present (email, name, phone, address) |
None |
E-mail patterns in feedback_text |
0 matches |
Phone-number patterns in feedback_text |
0 matches |
Postcode patterns in feedback_text |
0 matches |
user_pseudo_id / session_id are pseudonymous hex tokens |
100% |
| All text valid UTF-8 (round-trip encode/decode) | 100% |
| Language tag matches market (en-GB↔UK, fr-FR↔FR, de-DE↔DE) | 0 mismatches |
| Rating within 1–5 | 100% |
Automated validation is part of the CI/CD pipeline; a failing check blocks the publish step.
4. Rights of data subjects
Although the published dataset is pseudonymised (and here also synthetic), the organisation maintains the ability to honour data-subject rights on the internal raw store:
- Right of access (Art. 15) and rectification (Art. 16): supported via the internal raw store keyed by the raw user id.
- Right to erasure (Art. 17): raw records are deleted on request; published pseudonymous records are re-issued after salt rotation to prevent linkage.
- Right to object (Art. 21): honoured via the consent/preference centre.
5. Consent & lawful basis
Feedback is collected under legitimate interest (Art. 6(1)(f)) with clear privacy notice, or under consent (Art. 6(1)(a)) where required by local law (e.g. France/CNIL and Germany/BDSG guidance on cookie and analytics consent). Analytics are privacy-by-default: no advertising-grade profiling.
6. Data Protection Impact Assessment (DPIA)
A DPIA was conducted for the live-feedback analytics processing. Key findings:
- Risk of re-identification: low after pseudonymisation + salt protection.
- Residual risk: pseudonymous linkage across time; mitigated by salt rotation and by publishing only analytical attributes.
- Data transfer: dataset is published on a public hub; because the data is pseudonymised/synthetic and contains no direct identifiers, this is considered compliant with the transfer safeguards under Chapter V when combined with the SCCs and the EU-US Data Privacy Framework where applicable.
This report is stored alongside the dataset for audit purposes and is reviewed on every major release cycle.