D’LIGHT Law Group advised data analytic service providers on the combination of pseudonymized personal information with other external information.
Data analytic service providers must comply with the requirements and procedures set forth under the Personal Information Protection Act (“PIPC”) if a combination of data constitutes a combination of pseudonymous data under the PIPC.
Even if the combination of data does not constitute a combination of pseudonymous data under the PIPC, data analytic service providers must comply with PIPC regulations on the processing of pseudonymized data if the data includes any pseudonymous data.
Accordingly, data analytic service providers that use pseudonymous information should obtain detailed legal advice on the PIPC.