Why does label data need to be anonymized?
The courier label may include name, address, telephone number and shipment identifiers. The data must be effectively deleted before further sale.
The recipient's details are not part of the commercial value of the parcel. Disclosing them to a subsequent buyer creates unnecessary risk for the person to whom they concern and for entities participating in the trade in goods.
What data is on the label
The label may include your name, address, phone number, email, shipping code, order number or QR code leading to additional information. The combination of several elements may enable the identification of a person.
The Personal Data Protection Office reminds that personal data also includes information allowing the identification of a person indirectly.
- name and surname
- address and telephone number
- shipment IDs
- barcodes and QR codes
Anonymization must be effective
Simply partially blurring the name will not be enough if the address, code or embossed print can still be read. The Personal Data Protection Office indicates that anonymization should prevent the identification of a person.
The method must be matched to the paper, foil, tape and type of print. After completing the process, perform a visual inspection and test reading against the light.
- unable to read
- deleted codes leading to data
- control on both sides
- durability of the method used
Removing or covering
The safest option may be to physically remove the label or part of the packaging, as long as it does not compromise the safety of the product. For permanent covering, use a method that cannot be easily wiped or peeled off.
A thin marker may not be enough. On laminated labels, the ink may rub off and the data remains legible at an angle.
- tearing off the label
- permanent coverage
- barcode destruction
- readability check
Enter your warehouse procedure
Set up a separate place for shipments before and after anonymization. The employee should know which fields to delete, how to check the effect and what to do with the detached labels.
On a large scale, use sample control and batch register to be able to demonstrate how the goods were prepared.
- pre- and post-process area
- job instructions
- safe waste
- quality control
Communication and consequences of violation
Covered labels are not a defect. Explain to the customer that the recipients' data has been deleted or permanently anonymized. Don't show readable data in photos or videos posted online.
In Poland and throughout the EU, the supervisory authority can order remedial action, restrict processing and impose penalties. The GDPR provides for maximum levels of up to EUR 10 million or 2% of global turnover and - for the most serious breaches - up to EUR 20 million or 4% of turnover. This is not an automatic penalty for each label; each case is assessed individually.
- clear information about anonymization
- no data on the materials
- corrective actions of the authority
- maximum penalties under the GDPR
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