As data protection requirements evolve, HR professionals must balance effective people management with safeguarding sensitive employee data. The ICO’s newly published guidance on anonymisation and pseudonymisation offers practical ways to reduce risk, ensure compliance, and build trust. Here’s what HR consultants and their clients need to know — and how to apply it.

What’s the Difference Between Anonymisation and Pseudonymisation?

Anonymisation means removing or modifying personal data so that individuals can no longer be identified — even when combining it with other information. Once data is truly anonymised, data protection laws no longer apply.

Pseudonymisation involves replacing identifiers (like names, emails, or NI numbers) with reference codes or numbers. This makes re-identification harder, but the data is still considered personal and protected under the law.

Why This Matters for HR

HR teams process vast amounts of personal data — from performance metrics to health disclosures. Here’s how these techniques help:

• Internal Surveys: Anonymise responses to encourage honest feedback without breaching privacy.
• Performance & Pay Analysis: Use pseudonyms to study trends while masking individual identities.
• Outsourcing & Vendor Sharing: Share pseudonymised data with payroll providers or consultants safely.

Benefits Beyond Compliance

• Reduce breach impact: If data is accessed unlawfully, pseudonymised info limits exposure.
• Improve data ethics: Show staff you take their privacy seriously.
• Drive innovation: Safely explore trends and improve HR services using anonymised data.

What HR Consultants Should Do

1. Advise clients on when to anonymise or pseudonymise data
2. Help establish clear governance policies
3. Review tools and systems for privacy-enhancing capabilities
4. Use the ICO’s guidance as a benchmark for best practices

Check out the quick-reference infographic for a simple summary you can keep or share with clients.

Get the Full ICO Guidance

The ICO’s new guidance offers detailed technical and legal insights, along with real-world examples. Read the full guidance.

Coming Soon: Free Webinar

The ICO is hosting a webinar on Thursday 22 May 2025 with expert advisors discussing the guidance and answering questions. We encourage HR professionals to register for the webinar.

Author: Mary Asante | HRi