De-identification of data refers to the process used to prevent personal identifiers from being connected with information. The FTC indicated in its 2012 report Protecting Consumer Privacy in an Era of Rapid Change: Recommendations for Businesses and Policymakers that the FTC’s privacy framework only applies to data that is “reasonably linkable” to a consumer.1 The report explains that “data is not ‘reasonably linkable’ to the extent that a company: (1) takes reasonable measures to ensure that the data is de-identified; (2) publicly commits not to try to re-identify the data; and (3) contractually prohibits downstream recipients from trying to re-identify the data.”2identiyf