Yes, if genuine anonymisation is feasible; however, technical testing is essential and your contracts may provide otherwise. In most cases, a contract update + transparency is the cleanest path.
Mind one step that is easy to skip: the act of anonymising is itself a processing operation, so it needs its own lawful basis and a purpose-compatibility check before the identifiers come off. Do that assessment — and confirm your contracts permit the re-use — and anonymised training data becomes a clean, durable foundation rather than a later liability.
Shall we apply this matter to your situation?
Tell us your specific situation in a few sentences; we'll assess it with the right team.
This content is for general information only and does not constitute legal advice. Please contact our team for an assessment of your specific circumstances.
Categories