The Ministry of the Interior and Safety announced on June 3, 2020 the draft Notification on Combination and Removal of Pseudonymized Data (the "Draft Notification") and started seeking opinion from interested parties.  The Draft Notification sets out more detailed descriptions and guidelines concerning, among others, combination of pseudonymized data owned by different data controllers and removal of the combined data from the premises of an "expert organization" which is allowed to combine pseudonymized data.  The deadline for submitting opinion on the Draft Notification is June 16, 2020.  

Article 28-3 of the amended Personal Information Protection Act provides that only an "expert organization" designated by the relevant central government agency can combine pseudonymized data owned by different data controllers.  Such combination should, in principle, take place only within the premises of the expert organization, and removal of the combined data outside the expert organization requires approval of the expert organization.  The Draft Notification sets out the detailed requirements for the procedure and method of combining pseudonymized data, removal of the combined data, and approval for the removal.  Please refer to the attachment for key details.