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Guidance·EDPBNL
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Guidance

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Since effective pseudonymisation can mitigate adverse effects of data breaches, it may also be considered when assessing the obligations a controller has under Art. 33 and 34 GDPR. In particular, it may be regarded as an appropriate technical and organisational measure that limits the impact of a personal data breach in the sense of Art. 34(3)(a) GDPR. However, the content of data that was accessed without authorisation can still be analysed by the actor who accessed it. Careful analysis is required in this case to establish whether the pseudonymisation has reduced the risks resulting from the data breach sufficiently to render communication of the breach to the affected data subjects unnecessary, Art. 34(1) and (3) GDPR. 15 2.4.3 Pseudonymisation as a supplementary measure for third country data transfers

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