More or less personal…

https://fpf.org/blog/rethinking-personal-data-the-cjeus-contextual-turn-in-edps-vs-srb/

Rethinking Personal Data: The CJEU’s Contextual Turn in EDPS vs. SRB

On 4 September 2025, the Court of Justice of the European Union (CJEU) delivered its judgment in EDPS v SRB (C-413/23), which is a ground-breaking judgment regarding the interpretation of the concept of “personal data” under EU data protection law. This concept is central to the EU data protection legal framework and holds considerable importance for its implementation in practice. The SRB judgment is remarkable as it clearly departs from the long-standing position of data protection authorities, which have treated pseudonymized data as invariably personal data.

… In its decision, the Court provided three critical clarifications: 

• Opinions or personal views are “personal data” since they are inherently linked to their author (para. 60). 

• The concept of “personal data” is relative. Pseudonymized data are not always personal; their classification depends on the perspective of the actor processing them (paras. 76–77, 86). 

• The controller’s duty to provide notice applies ex ante at the time of collection, before the data have undergone pseudonymization, and must be assessed from the controller’s standpoint, regardless of whether the recipient can re-identify it (paras. 102, 112).