Techniques to achieve anonymization of health data: When are they sufficient to be considered as legally complaint?

o protect the data privacy of individuals, various legisla-
tive instruments prescribed the anonymization or pseudo-anonymization
of data before such data may be shared for purposes including health re-
search. However, the mere mention of this requirement is not sufficient.
Considering the rapid development in both anonymization techniques,
including re-identification attacks and the ease with which they can be
implemented as a result of data aggregation, it is important to find con-
sensus about the meaning of anonymization and, most importantly what
techniques are considered to be sufficient to achieve true anonymization
for purposes of data sharing and secondary use of data as advocated for
in the European Health Data Space proposal. In this paper, we investi-
gate the current state of the terminology used and how it is approached
in different legal instruments and then consider this against the aims
and goals of the European Health Data Space proposal. Lastly, we shall
consider the available and potential techniques that may be valuable in
anonymizing data for purposes as contemplated in the European Health Data Space proposal.