# Processing which does not require identification — GDPR — context bundle > Focused context for a single provision, curated from overview.legal on 2026-08-22. Canonical page: https://overview.legal/laws/gdpr/art-11 > Every item cites its source. Verify against the official text (EUR-Lex / wetten.overheid.nl) before relying on it. ## Provision ### Processing which does not require identification — Processing which does not require identification *GDPR, gdpr-art-11-en — https://overview.legal/laws/gdpr/art-11* 1. If the purposes for which a controller processes personal data do not or do no longer require the identification of a data subject by the controller, the controller shall not be obliged to maintain, acquire or process additional information in order to identify the data subject for the sole purpose of complying with this Regulation. 2. Where, in cases referred to in paragraph 1 of this Article, the controller is able to demonstrate that it is not in a position to identify the data subject, the controller shall inform the data subject accordingly, if possible. In such cases, Articles 15 to 20 shall not apply except where the data subject, for the purpose of exercising his or her rights under those articles, provides additional information enabling his or her identification. ## Related recitals ### Recital 153 — reconciling data protection with freedom of expression Member States law should reconcile the rules governing freedom of expression and information, including journalistic, academic, artistic and or literary expression with the right to the protection of personal data pursuant to this Regulation. The processing of personal data solely for journalistic purposes, or for the purposes of academic, artistic or literary expression should be subject to derogations or exemptions from certain provisions of this Regulation if necessary to reconcile the right to the protection of personal data with the right to freedom of expression and information, as enshrined in Article 11 of the Charter. This should apply in particular to the processing of personal data in the audiovisual field and in news archives and press libraries. Therefore, Member States should adopt legislative measures which lay down the exemptions and derogations necessary for the purpose of balancing those fundamental rights. Member States should adopt such exemptions and derogations on general principles, the rights of the data subject, the controller and the processor, the transfer of personal data to third countries or international organisations, the independent supervisory authorities, cooperation and consistency, and specific data-processing situations. Where such exemptions or derogations differ from one Member State to another, the law of the Member State to which the controller is subject should apply. In order to take account of the importance of the right to freedom of expression in every democratic society, it is necessary to interpret notions relating to that freedom, such as journalism, broadly. ## Enforcement 7 decision(s) on record cite Article 11, totalling approximately €106,000 in fines (median €15,000). Top fines: - **INFO COMMUNICATION SERVICES: Insufficient fulfilment of information obligations** (GREECE, €30,000) — https://overview.legal/posts/47101 - **One Way Private Company: Insufficient technical and organisational measures to ensure information security** (GREECE, €30,000) — https://overview.legal/posts/47072 - **PLUS REAL ADVERTISEMENT: Insufficient fulfilment of information obligations** (GREECE, €25,000) — https://overview.legal/posts/47100 - **Flamel S.r.l.: Non-compliance with general data processing principles** (Italy, €15,000) — https://overview.legal/posts/53569 - **Candidate for parliamentary elections: Insufficient fulfilment of data subjects rights** (GREECE, €2,000) — https://overview.legal/posts/46741 ## Guidance ### Guidelines on processing of personal data through blockchain technologies *EDPB — https://overview.legal/posts/125668* Guidelines 02/2025 on processing of personal data through blockchain technologies Version 2.0 Adopted on 07 July 2026 1 | Adopted Version history Version Date Adoption information version 1.1 08 April 2025 adoption of the guidelines before public consultation version 2.0 07 July 2026 adoption of the guidelines after public consultation 3 | Adopted 4 | Adopted The European Data Protection Board Having regard to Article 70 (1)(e) of the Regulation 2016/679/EU of the European Parliament and of the… ### Opinion 14/2026 on the Europrivacy certification criteria regarding their approval by the Board as European Data Protection Seal pursuant to Article 42.5 GDPR *EDPB — https://overview.legal/posts/125682* Opinion 14 / 2026 on the Europrivacy certification criteria regarding their approval by the Board as European Data Protection Seal pursuant to Article 42.5 GDPR Adopted on 15 April 2026 1 | Adopted 2 | Adopted The European Data Protection Board Having regard to Article 63, Article 64 (2) and Article 42 of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free… ### EDPB Annual Report 2025 *EDPB — https://overview.legal/posts/125683* Clarity in action: Supporting stakeholders through guidance and dialogue Annual Report 2025 Foreword 3 Highlights 4 1. The EDPB Secretariat 6 1.1 Mission And Activities 8 2. European Data Protection Board – Activities in 2025 12 2.1 Bridging Fundamental Rights and Digital Innovation Through GDPR Compliance 12 2.1.1 Helsinki high-level meeting: enhanced clarity, support and engagement 12 2.1.2 Regulation on procedural rules and Omnibus regulation on the record of processing 14 2.1.3 Cross… ### Report on stakeholder event on processing of personal data to target or deliver political advertisements *EDPB — https://overview.legal/posts/125684* Report on stakeholder event on processing of personal data to target or deliver political advertisements 27 March 2026 1. Background The EDPB organised an online stakeholder event on 27 March 2026 to collect stakeholders’ input on processing of personal data to target or deliver political advertisements. The objective was to engage with stakeholders at an early stage of drafting the EDPB Guidelines on the processing of personal data to target or deliver political advertisements (Chapter III of… ### EDPB-EDPS Joint opinion 2/2026 on the Proposal for a Regulation as regards the simplification of the digital legislative framework ( *EDPB — https://overview.legal/posts/53739* EDPB, EDPB-EDPS Joint opinion 2/2026 on the Proposal for a Regulation as regards the simplification of the digital legislative framework (Digital Omnibus) ## Related topics - **Identification** — https://overview.legal/topics/identificatie ## Legal Framework --- Generated by overview.legal · https://overview.legal/laws/gdpr/art-11 · 2026-08-22