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Pseudonymisation or anonymisation – what's the difference, and what does GDPR require?

GDPR and AILast updated 2 min read

Short answer

Pseudonymisation replaces names and other identifiers with codes, while the key is kept separately. The data is still personal data for whoever holds the key. Anonymisation removes any way of identifying the person at all – and anonymous data falls outside GDPR. True anonymisation is hard, especially with free text. Pseudonymisation, on the other hand, is named in GDPR as an important safeguard, and in 2025 the Court of Justice of the EU (Case C-413/23 P) confirmed that whether data is personal data for a recipient depends on whether that recipient can realistically identify the people.

Try it yourself

Type some text and see it pseudonymised. The text never leaves your browser.

Try it yourselfGoalCube Data Vault
What the AI sees

[PERSON_1]…

The text never leaves your browser. This is a simplified version of GoalCube’s protection.

Pseudonymisation across a whole dataset

GoalCube Data VaultFictitious data
Dataset
Show
Your dataStays in the EU with GoalCube
CustomerEmailLocationTopic
Sarah Murphysarah.murphy@example.comCorkRefund
Daniel Kellydaniel.kelly@example.comGalwayDelivery
Claire Walshclaire.walsh@example.comLimerickComplaint
Thomas Camillerithomas.camilleri@example.comSliemaDelivery
Emma Byrneemma.byrne@example.comDublinRefund

Enquiry Hi, my name is Sarah Murphy and I returned order 7012345678 two weeks ago, but I still haven't received my money. Please transfer it to IE29 AIBK 9311 5212 3456 78. Kind regards, Sarah

What the AI seesIn ChatGPT, Claude or Copilot
CustomerEmailLocationTopic
[PERSON_1][EMAIL_1][STED]Refund
[PERSON_2][EMAIL_2][STED]Delivery
[PERSON_3][EMAIL_3][STED]Complaint
[PERSON_4][EMAIL_4][STED]Delivery
[PERSON_5][EMAIL_5][STED]Refund

Enquiry Hi, my name is [PERSON_1] and I returned order [ID_1] two weeks ago, but I still haven't received my money. Please transfer it to [IBAN_1]. Kind regards, [PERSON_1]

Task for the AI: Find the most urgent cases and suggest a reply.
The answer in GoalCubeNames filled back in, only on your side

Sarah Murphy and Emma Byrne are waiting for a refund and should get a reply today. Thomas Camilleri has waited 10 days for a parcel. Suggested reply to Sarah Murphy: "Dear Sarah Murphy, thank you for your patience. Your money is on its way and will be in your account within 5 working days."

The AI’s answerPseudonyms only

[PERSON_1] and [PERSON_5] are waiting for a refund and should get a reply today. [PERSON_4] has waited 10 days for a parcel. Suggested reply to [PERSON_1]: "Dear [PERSON_1], thank you for your patience. Your money is on its way and will be in your account within 5 working days."

23 sensitive values hidden from the AINo real names left the EU
Your dataStays in the EU with GoalCube
CandidateBornID numberEmployerExperience
Louise Brennan1985-03-121234567TAShannon Timber Ltd12
Michael Doyle1992-11-022345678KBLiffey Logistics Ltd4
Maria Borg1988-06-210123488MGrand Harbour Metals Ltd9
David Fenech1979-01-300456779MValletta Pharma Ltd18

CV Louise Brennan has 12 years' experience in budgeting and monthly reporting at Shannon Timber Ltd. She implemented a new ERP system and leads a team of three. Contact: louise.brennan@example.com.

What the AI seesIn ChatGPT, Claude or Copilot
CandidateBornID numberEmployerExperience
[PERSON_1]40–49 years[ID_1][VIRKSOMHED_1]12
[PERSON_2]30–39 years[ID_2][VIRKSOMHED_2]4
[PERSON_3]30–39 years[ID_3][VIRKSOMHED_3]9
[PERSON_4]40–49 years[ID_4][VIRKSOMHED_4]18

CV [PERSON_1] has 12 years' experience in budgeting and monthly reporting at [VIRKSOMHED_1]. The person implemented a new ERP system and leads a team of three. Contact: [EMAIL_1].

Task for the AI: Assess the candidates against the job advert.
The answer in GoalCubeNames filled back in, only on your side

Louise Brennan and Maria Borg have more than 5 years' experience and should be invited to interview; ask Maria Borg about experience with ERP systems. Michael Doyle has 4 years' experience; the requirement is 5. A person makes the decision.

The AI’s answerPseudonyms only

[PERSON_1] and [PERSON_3] have more than 5 years' experience and should be invited to interview; ask [PERSON_3] about experience with ERP systems. [PERSON_2] has 4 years' experience; the requirement is 5. A person makes the decision.

20 sensitive values hidden from the AINo real names left the EU
Your dataStays in the EU with GoalCube
SupplierContactAccountExpires
Atlantic Components LtdPeter WalshIE64 IRCE 9205 0112 3456 782027-01-31
Malta Data Hosting LtdAnna GrechMT84 MALT 0110 0001 2345 MTLC AST0 01S2026-12-31
Midlands Precision LtdSimon NolanIE12 BOFI 9000 0112 3456 782028-06-30
Celtic Packaging LtdNicole RyanIE02 AIBK 9310 6512 9876 542027-03-31

Terms Atlantic Components supplies specialist components for Project Skellig. The price is adjusted annually by the consumer price index plus 3%. Liability is capped at 10% of the annual contract value. Contact Peter Walsh about any changes.

What the AI seesIn ChatGPT, Claude or Copilot
SupplierContactAccountExpires
[VIRKSOMHED_1][PERSON_1][IBAN_1]2027-01-31
[VIRKSOMHED_2][PERSON_2][IBAN_2]2026-12-31
[VIRKSOMHED_3][PERSON_3][IBAN_3]2028-06-30
[VIRKSOMHED_4][PERSON_4][IBAN_4]2027-03-31

Terms [VIRKSOMHED_1] supplies specialist components for [PROJEKT_1]. The price is adjusted annually by the consumer price index plus 3%. Liability is capped at 10% of the annual contract value. Contact [PERSON_1] about any changes.

Task for the AI: Find contracts that should be terminated or renegotiated.
The answer in GoalCubeNames filled back in, only on your side

Atlantic Components Ltd renews automatically unless it is terminated by 31 October. It is important for an internal project, so renegotiate the price rather than terminate. Celtic Packaging Ltd also renews automatically; the deadline is 31 December.

The AI’s answerPseudonyms only

[VIRKSOMHED_1] renews automatically unless it is terminated by 31 October. It is important for an internal project, so renegotiate the price rather than terminate. [VIRKSOMHED_4] also renews automatically; the deadline is 31 December.

21 sensitive values hidden from the AINo real names left the EU

Fictional data. Point to a name or a pseudonym to see what belongs together.

Why not just anonymise?

Because you need to use the answer. When the AI suggests that [PERSON_2] should get a reply today, you need to know who that is. With pseudonymisation, the name is put back in on your side – with anonymisation, the link is gone for good.

What to do

  1. Find the identifiers.Names, emails, phone numbers, ID numbers, account numbers, addresses.
  2. Replace them with fixed codes.The same person gets the same code throughout the dataset.
  3. Watch out for free text.Names and numbers hide in messages and CVs.
  4. Generalise anything that could identify someone.A date of birth becomes an age group, a town becomes a region.
  5. Keep the key separate.The key must never be sent to the AI.

What the law says

Article 4(5) GDPR – pseudonymisation
The definition: data that can no longer be attributed to a person without additional information, which is kept separately.
Recital 26 GDPR
Pseudonymised data is personal data; anonymous data is not.
Articles 25 and 32 GDPR
Pseudonymisation is named as an appropriate measure.
Court of Justice of the EU, Case C-413/23 P (EDPS v SRB), 4 September 2025
Whether pseudonymised data is personal data for the recipient depends on the recipient's realistic means of identifying the people.

Questions and answers

Is data anonymous once the name is removed?

Rarely. Age, place of residence, job and free text can often give the person away. These are called quasi-identifiers.

Is pseudonymised data personal data for the AI provider?

It may or may not be, depending on the provider's realistic means of identifying the people. For you, holding the key, it is always personal data.

What does GoalCube do with free text?

GoalCube finds names, emails, phone numbers, addresses, ID numbers from EU countries and account numbers in free text, hides your secret words and writes gender neutrally.

Sources

Written by The GoalCube editorial team. Last updated 11 October 2026. GoalCube helps you follow the EU AI Act and GDPR. It is not legal advice.

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