가명처리 과정에서 정보 주체의 직접적 참여정책 마련의 필요성에 대한 연구

A Study on the Necessity of Establishing Policies for Direct Participation of Data Subjects in the Pseudonymization Process

This study investigates the necessity of establishing a policy framework to ensure the direct participation of data subjects in the pseudonymization process, as stipulated in the Personal Information Protection Act and related data laws. While pseudonymization is a crucial technology that enables safe data utilization by removing identifiability, current legal provisions lack clarity regarding the procedures and responsibilities for implementing pseudonymization. This legal gap, combined with the limited involvement of data subjects, may lead to rights violations, reduced trust, and ethical risks. The study analyzes major legal issues such as the incomplete definition of pseudonymization, the legitimacy of processing data without consent, the boundary between pseudonymized and anonymized data, and the risk of re-identification. Based on this analysis, it proposes actionable measures: enhancing transparency, clarifying consent and withdrawal procedures, ensuring access and correction rights, and establishing feedback channels such as digital portals and customer centers. It also emphasizes the need for updated legal guidelines and ethical standards. These measures aim to strengthen data subjects’ rights, improve public trust, and promote sustainable data governance.