What is De-Identified Data in the New Jersey Data Protection Act (“NJDPA”)?
De-Identified Data is data that cannot be reasonably used to infer information about, or otherwise be linked to, an identified or identifiable individual, or a device linked to such an individual, if the controller that possesses the data: (a) takes reasonable measures to ensure that the data cannot be associated with an individual; (b) publicly commits to maintain and use the data only in a de-identified fashion and not to attempt to re-identify the data; and (c) contractually obligates any recipients of the information to comply with the requirements.
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