Aggregated Does Not Automatically Mean You’re Exempt
If your “aggregated” datasets can be linked back to individuals, locations, or devices, regulators may treat them as personal data and expect registration, disclosures, and deletion workflows.
The Evidence Question to Ask Yourself: Has anyone formally reviewed whether your “aggregated” products still carry re‑identification risk?
CLIClaw’s Compliance Program Library includes data broker applicability tools you can adapt to your own structure.
