Investor list redaction is the removal of personal data from the participant roster behind a raise. The roster exists to prove the offer stayed inside UK Prospectus Regulation Art. 1(4) — qualified investors, or fewer than 150 other persons — and to evidence the due diligence required by MLR 2017. What matters is the count and the certification, not the identities. anonym.plus marks each name, identifier and bank field on your machine, so the roster stays usable while buyers are shielded.
When this applies
The roster pairs each participant with a National Insurance number, a bank reference and a commitment figure. You strip those before the list reaches counsel, an auditor or the registrar.
How anonym.plus handles it
- Open the roster in anonym.plus on your device.
- Local OCR reads a scanned or printed list.
- The tool flags names, NINOs, and bank numbers.
- Keep the totals the raise must reconcile.
- Mask or swap each confirmed field.
- Save the clean roster locally.
What you need to provide
- The roster (CSV export, PDF, DOCX, or scan).
- An operator (Mask suits structured fields).
- Optional name map, kept under tight control.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | participant R. Pennington → [INVESTOR] |
| Identifiers | UK_NINO | tax NINO → [NINO] |
| Financial | UK_BANK_NUMBER | funding acct → [ACCOUNT] |
| Money | MONEY | commit £500k → [AMOUNT] |
| Contact | EMAIL_ADDRESS | buyer@example.co.uk → [EMAIL] |
| Location | LOCATION | home address → [ADDRESS] |
Compliance achieved
- The 150-person count in UK Prospectus Regulation Art. 1(4) is why the roster exists — keep the count, not the identities.
- Pre-emption rights under CA 2006 s.561, and any disapplication under s.570, govern the allocation; those facts stay.
- NINO and bank fields are gathered for MLR 2017 regs. 27 and 28 due diligence, not for onward sharing.
- Investor-certification wording under the Financial Promotion Order 2005 survives the pass; the certifying individual does not have to.
- Data minimisation under UK GDPR Art. 5(1)(c) is the test for what an adviser actually needs to see.
Anonymise investor lists offline — see plans & start free →
Limitations & cautions
A rare, large commitment can single out a participant even after the name goes. The tool flags named fields; distinctive amounts are your judgment call. Keep an unredacted master for the MLR 2017 and registrar records.
Frequently asked questions
Will the raise totals survive the pass?
Yes. Allow-list the totals you must reconcile. Only personal identifiers in each row are flagged for removal.
Why does the head count matter more than the names?
Because UK Prospectus Regulation Art. 1(4) turns on how many non-qualified investors were approached — fewer than 150 — not on who they were.
Does the roster leave my machine?
No. The app is offline, so each buyer's data stays on your device.