13/72 111972/2020/CL&ES
4. Definition of Non-Personal Data and Key Roles It is thus understood that data is valuable and it must be regulated in an appropriate manner. For that to happen, a clear definition of Non-Personal Data and key roles in the Non-Personal Data ecosystemmust be articulated.
Definition of Non-Personal Data 4.1. Accordingly, the Committee considered various kinds and aspects of Non-Personal Data. Refer to Appendix 2 for the information / examples of Non-Personal Data that the Committee considered.
i. Data may be categorised in many ways – arising from the subject of data (e.g. personal data); in relation to its purpose (e.g. AI training data, e-Commerce data); the sector to which it belongs (e.g. health data); the source of data (e.g. soil data); level of processing (raw / factual versus derived data); or the collector of data (e.g. public / Government or private data); or based the extent of involvement of stakeholders in the creation of data (provided, observed, derived, or inferred).
ii. Non-Personal Data – When the data is not ‘Personal Data’ (as defined under the PDP Bill), or the data is without any Personally Identifiable Information (PII), it is considered Non-Personal Data.
iii. A general definition of Non-Personal Data according to the data’s origins29 can be: o
o
Firstly, data thatnever related to an identified or identifiable natural person, such as data on weather conditions, data from sensors installed on industrial machines, data from public infrastructures, and so on. Secondly, data which were initially personal data, but were later made anonymous. Data which are aggregated and to which certain datatransformation techniques are applied, to the extent that individualspecific events are no longer identifiable, can be qualified as anonymous data.
iv. Given the importance of anonymisation (of Personal Data to make it NonPersonal Data) and to prevent the risk of re-identification, the Committee collated some of the basic anonymisation techniques in this report. Refer to Appendix 3.
29 European Commission, “Guidance on the Regulation on a framework for the free flow of Non-Personal Data in the European Union”, 2019, https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52019DC0250&from=EN
13
