Should the data contained in the Housing Cooperative Board's minutes be anonymised? On what legal basis?

ANSWER

Anonymisation and pseudonymisation of personal data are technical measures intended to enable the data controller to ensure an appropriate level of security. The controller decides when to apply them, depending on the situation. There is no provision of law that requires anonymisation of personal data in specific cases. If therefore resolutions of the Housing Cooperative Board are as a rule available to all members of the cooperative and every member has the right to familiarise themselves with the full content of a resolution, anonymisation for the purpose of publishing it on a website to which only members of a specific cooperative have access is not required — provided however that access is restricted to members of the Housing Cooperative who have specific logins and passwords, as indicated. If the same resolution were to be published on a publicly accessible website, anonymisation would already be necessary. Otherwise the controller may face an allegation of a breach of personal data protection.