Beyond names
An identifier, location or combination of details can identify someone. Assess the available context, not an isolated field.
FinFly Explains / IT
What personal data means
ICO offers a useful criterion: information relates to a person identifiable directly or indirectly. This is the UK regulator’s framework, not a statement of Azerbaijani law.
Replacing names with codes
ICO’s example remains pseudonymisation when the organisation can reconnect codes to people. That differs from effectively anonymised information.
A practical check
FinFly recommends checking what a partner could match your table against before sharing it. Record who retains the code-to-person mapping separately.
Which rules apply
A definition frames the question but does not establish whether collection or sharing is lawful. Check the relevant jurisdiction; ICO also flags its guidance as under review.
Questions
Short answers
Does deleting names remove all personal data?
Not necessarily. Other details or combinations may still identify people.
Method
Primary sources
The explainer is checked against these institutional and industry sources. Links open the original material.