World423_JS_01

Let's assess the applicability of the statement of "[t[hese data elements constitute personal data for GDPR purposes because they relate to identifiable users, even though no directly identifying attributes (e.g., names or email addresses) were included," to BlueQuill.  

This statement is located in the Analytics Module Supervisory Document. 

Assess whether BlueQuill actually processed personal data under the GDPR when it received the data transfer from the "Diagnostics Analytics Module". Blue...

No, BlueQuill did not process personal data under the GDPR. Although the Analytics Module Supervisory Document states that user_uuid and device_id "constitute personal data for GDPR purposes," that assessment was made from Northstar's perspective as the data controller. 

Under the GDPR, information constitutes personal data only if two cumulative conditions are met: (1) the information relates to a natural person, and (2) that natural person is identifiable. 

Under Breyer v. Germany and its application in Single Resolution Board v European Data Protection Supervisor, a recipient does not process personal data if the recipient does not have reasonable means to identify a natural person from the pseudonymized data.

Here, BlueQuill did not have access to NorthStar's data that would enable BlueQuill to identify the natural person linked to the pseudonymized data. Accordingly, BlueQuill did not process personal data under the GDPR.