“A Rose by any Other Unique Identifier”: Regulating Consumer Data Tracking and Anonymisation Claims

Representations in online privacy policies that certain data is anonymous or “not information that personally identifies you” can have significant consequences. They may indicate that the firm considers the data to be outside the scope of data protection regulation, and/or give consumers the impression that this is data which cannot have an impact on the individual; for example, that it will not add to the individual consumer’s profile. However, there are a growing range of data practi