As data custodians, we provide an intermediary activity between you as the service provider on the one hand and the data subjects on the other hand, in order to enable you to process sensitive data that cannot be attributed to the subject in question. In particular in the context of medical research, the appointment of a data custodian constitutes a common procedure for the purpose of processing data concerning health while respecting the personal rights of the patients and the research participants.
In those cases, we replace the identity of the data subjects with a pseudonym, so that only we as the data custodians are able to perform an individual-related attribution of the data. Thus, when dealing with pseudonymized data, as opposed to dealing with anonymized data, the reference to an individual person is not completely removed, but is rather attributed by means of an identifier. Thus, the processing of the personal data is carried out by the data recipient without a disclosure of identities, and this constitutes an effective means within the meaning of the GDPR for the protection of data subjects.
In addition to the necessary know how, we provide the required technical equipment to ensure a data protection compliant pseudonymization and, as a result of this, a lawful processing of sensitive data. After the pseudonymized data processing has been carried out by your service provider, we will carry out the necessary de-pseudonymization, in order to enable you to perform an individual-related analysis and further processing of the personal data.
Please contact us if you are considering a custodianship when dealing with data that need particular protection.