“No names”
is only the beginning.
Imagine a small workplace. The report shows that a heat product was taken from the cabinet by the back door on Tuesday at 06:12. The manager knows who opened up that morning.
The name field is empty. The data can still point to one person. A pick-up is not proof of who will use the product either, or why.
“This product will soon need refilling.”
Product + exact time + location + a link to a shift roster.
Aggregated statistics can also become revealing if they are cut into small enough pieces. There is no fixed number of employees that always makes a report anonymous.
Find out what is actually stored in the cabinet, at the supplier and in the reports. A tidy overview with no names says little about the data behind it.
Limit the data and the recipients, and agree when data is deleted. Consider whether coarse overviews or refill alerts alone are enough. If people can still be recognised, the data must be handled under data protection rules.
Principles: EDPB guide for small businesses →