Instructions on the anonymisation of test data

1 Key terms

Anonymisation Anonymisation means that personal data is processed such that the person cannot be identified on the basis of the data under any circumstances. Also, it must be impossible to convert the data back into an identifiable form.

Pseudonymisation Pseudonymisation means that personal data is converted such that it cannot be attributed to a specific person without the use of additional information. A requirement is that the additional information is kept separately and that it is subject to technical and organisational measures ensuring that the personal data cannot be connected to an identified or identifiable natural person.

Pseudonymised data is still personal data and its processing is subject to the data protection regulations. In other words, the person can be identified by combining data from different datasets even though the data has been pseudonymised.

GDPR General Data Protection Regulation (EU) 2016/679.

2 Instructions on the anonymisation of test data

These instructions provide the information needed to anonymise test data used in testing. The instructions are for organisations participating in the Positive credit register’s stakeholder testing.

The data used in testing may not be connectable to natural persons or their data. In anonymisation, the data is made unidentifiable such that a person cannot be identified on the basis of the data in any situation, and the data cannot be converted back to the original state by any means. Personal identity codes or other data that can be connected to natural persons may not be sent as test data under any circumstances: the test data must always be anonymised.

If the data can be restored with a code key or by combining it with other data, the data in question is pseudonymised data. According to the GDPR, pseudonymised personal data that can be connected to a natural person with the use of additional information must be regarded as data relating to an identifiable natural person. Consequently, pseudonymisation is not enough but all test data must be fully anonymised.

All test IDs used in stakeholder testing are artificial business IDs or artificial personal IDs that the person who filled in the testing start notification receives from the Positive credit register’s administrator.

The stakeholders themselves are responsible for the anonymisation of their test data in every respect. Anonymisation must be carried out in accordance with these instructions.

3 Indentifiers used in testing

Testing stakeholders are provided with artificial lender’s Business IDs and names, artificial borrower’s personal IDs and Business IDs, and artificial reassignee’s business IDs and names.

The above-mentioned artificial personal IDs, Business IDs, their combinations, or artificial foreign business IDs must be used in testing. Natural persons’ actual personal data may not be used in testing under any circumstances. No identifiers that could be connected to natural persons by any means may be used in testing.

The stakeholder’s own artificial or anonymised identifiers cannot be used in testing.

4 Loan data to be reported to the register

During testing, stakeholders send test data connected to artificial personal identity codes to the testing environment through APIs. All test data submitted through APIs must be artificial or anonymised in accordance with these instructions. Loan number and lender’s name for marketing purposes, for example, must be anonymised.

5 Data to be anonymised and examples of anonymisation

Table 1 below specifies the data content to be anonymised and any special features that should be taken into account in the anonymisation, such as various requirements for the format. All data in the table must be anonymised. The table also contains some examples for anonymisation.

Table 1. Data to be anonymised, requirements and reasons for anonymisation. The testing stakeholder connects anonymised data to artificial identifiers that the Positive credit register has provided for purposes of testing.