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  • Administrative Pre-announcement of Partial Amendment to the Notice on the Combination and Transfer, etc. of Pseudonymized Information
    • Competent Ministry : Personal Information Protection Commission
    • Advance Publication of Legislation : 2023-11-09
    • Opinion Submission Deadline : 2023-11-29

1. Reasons for Amendment

○ This Amendment takes follow-up measures and makes other amendments to the Notice in accordance with the “Measures to Expand the Utilization of Pseudonymized Information” formulated in July based on suggestions for improvement from the industry to promote the use of pseudonymized information. 



2. Major Provisions

A. Clarify the review period for changes to specialized combination agencies (Article 5 (7))

○ Prevent unnecessary delays change reviews by prescribing that any changes to designation requirements reported by a specialized combination agency to the designating authority shall be reviewed within a certain time (one month).


B. Expand allowable purposes of self-combination by specialized combination agencies (Article 9-4, Article 12) 

○ Allow agencies specializing in the combination of pseudonymized information to self-combine data for self-utilization purposes, and prescribe supplementary devices* to prevent abuse/misuse of the system.


* [Supplementary devices] (1) Compulsory participation of similar competing agencies in transfer reviews to prevent leniency in the implementation of combination procedures (2) Public announcement of self-combination records (3) Self-combination permitted in proportion to the provision of pseudonymized information to third parties


C. Streamline designation requirements (staffing standards) for specialized combination agencies (attached Table 1)

○ Ease staffing burdens, etc. by expanding the areas of recognized experience for specialists and subcategorizing and recognizing additional experience requirements in the designation criteria for specialized combination agencies. 


D. Reflect modifications in the amended (enforced on September 22, 2023) Standards on Measures to Ensure the Safety of Personal Information (attached Table 1)

○ Reflect deletions (Article 10 Safety Measures for Administrative Devices) and simple rewordings in relation to designation standards for specialized combination agencies in the Standards on Measures to Ensure the Safety of Personal Information. 


E. Extend the regulatory review deadline (Supplementary Provisions, Article 13)

○ Extend the regulatory review period from two years to three years to ensure sufficient reviewing of regulatory effects as the nature of pseudonymized information makes it difficult for regulatory impacts to become apparent immediately.

Regulatory effect assessment
  • 가명정보의 결합 및 반출 등에 관한 고시(규제영향분석서)_20231110.hwp [download]
Legislative proposal (draft)
  • 행정예고 공고문(제2023-94호).hwp [download]