The Court of Justice of the European Union recently issued a decision expanding obligations around handling of pseudonymized data, while clarifying that pseudonymized data is not always personal data – supporting the use of such data to train AI. This article, with insights from experts at Bird & Bird, Clifford Chance, Dentons and Jones Day, examines the practical implications of the decision’s key holdings around pseudonymous data, and discusses some of the outstanding uncertainties, anticipated regulatory guidance and how companies can prepare to update their practices. See “Managing Data Transfers After Latombe” (Oct. 8, 2025).