Shareholder communication redaction is the removal of personal data from a holder mailing and the file behind it. The register of members itself is defined by Companies Act 2006 s.113, and it may be inspected only for a proper purpose under s.116 — which tells you how tightly the underlying data is controlled. A marketing or analysis copy needs far less. anonym.plus marks each name, address and holding on your machine, so the message stays clear while holders go unnamed.
When this applies
A mailing merges holder names, addresses and share counts into each letter, and the merge file is then reused for turnout analysis. You strip the identifiers before that reuse or before the file is archived.
How anonym.plus handles it
- Open the merged letters in anonym.plus on your device.
- Local OCR reads scanned response cards.
- The tool flags names, addresses, and holdings.
- Turn the name map off for a truly anonymous set.
- Swap or black out the confirmed entries.
- Save the clean letters locally.
What you need to provide
- The mailing (DOCX merge, PDF, CSV, or scan).
- An operator (Redact suits anonymisation).
- Optional batch for a full mailing run.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | holder C. Davenport → [HOLDER] |
| Location | LOCATION | mailing address → [ADDRESS] |
| Money | MONEY | 1,200 shares → [HOLDING] |
| Contact | EMAIL_ADDRESS | holder@example.co.uk → [EMAIL] |
| Identifiers | NATIONAL_ID | investor ref → [ID] |
| Dates | DATE_TIME | record 04/2025 → [DATE] |
Compliance achieved
- The register's own contents are fixed by CA 2006 s.113; a mailing or analysis extract needs far less than that.
- Inspection meets the proper-purpose test in CA 2006 s.116, with five working days to comply or apply to the court under s.117.
- Major-holding notifications under the FCA DTR 5 regime are public from 3%, then at each 1% band; the rest of a holder file is not.
- A director's usual residential address is protected information under CA 2006 ss.240-246 — never let one into a mailing file.
- Reuse for analysis rests on UK GDPR Art. 6(1)(f), or drops out of scope entirely on the Recital 26 test with the map off.
Anonymise shareholder communications offline — see plans & start free →
Limitations & cautions
Recital 26 treats data as anonymous only if no one can re-identify it by likely means, and a large or unusual holding can single out a person even without a name. Mask or band outliers, and keep the statutory register itself untouched.
Frequently asked questions
When does a mailing count as anonymous under Recital 26?
When no one can re-identify a holder by any reasonably likely means. Turn the name map off and band rare holdings, not only names.
Can I redact the register of members?
No. CA 2006 s.113 fixes what the register must contain, and s.116 controls who may see it. Clean the mailing or analysis extract instead.
Is the holder list uploaded?
No. The app is offline, so each holder's data stays on your device.