Renewal redaction is the removal of personal data from a continuation mailing. Since 1 April 2017 the FCA's renewal rules in ICOBS 6 have required last year's premium to be shown next to the proposed one, with a shop-around message after four consecutive renewals. Since 1 January 2022 the pricing rules made under PS21/5 have stopped an insurer quoting a renewing customer more than the equivalent new-business price. Both are tested on the figures, not on the name.
When this applies
Such a mailing repeats the holder's name, account, and address alongside the two premium figures. An audit reviewer or a vendor needs the figures and the disclosure wording. You trim the personal fields before the notice moves on.
How anonym.plus handles it
- Open the notice in anonym.plus on your device.
- Local OCR reads a scanned mailing page.
- The tool flags names, accounts, and addresses.
- Keep the premium and cover terms intact.
- Swap or black out the confirmed entries.
- Save the clean copy locally.
What you need to provide
- The continuation notice (PDF, DOCX, or scan).
- An operator (Replace keeps the terms readable).
- Optional allow-list for premium and policy numbers.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | the holder → [INSURED] |
| Financial | UK_BANK_NUMBER | billing acct 8830 → [ACCOUNT] |
| Location | LOCATION | mailing address → [ADDRESS] |
| Contact | EMAIL_ADDRESS | holder@example.co.uk → [EMAIL] |
| Financial | MONEY | premium £1,180 → [AMOUNT] |
| Dates | DATE_TIME | due date 2026 → [DATE] |
Compliance achieved
- Keeps both premium figures and the shop-around wording that FCA ICOBS 6 has required at renewal since 1 April 2017.
- Leaves the price data on which the general insurance pricing rules (PS21/5, in force 1 January 2022) are tested — the equivalent new-business price for a renewing customer.
- Supports the good-outcomes obligation of the FCA Consumer Duty (Principle 12, PRIN 2A), in force for open products since 31 July 2023.
- Removes holder name, billing account, and mailing address under UK GDPR Art. 5(1)(c).
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Limitations & cautions
A mailing address can hint at the holder even after the name goes. The tool flags named items and does not check whether the renewal price itself is compliant. Decide whether the address must be masked too.
Frequently asked questions
Can I keep the premium visible?
Yes, and you normally should. ICOBS 6 requires last year's premium next to this year's, and the pricing rules in force since 1 January 2022 are tested on exactly those figures.
Does UK GDPR apply to a continuation mailing?
Yes. The holder's name, address, and billing details are personal data. anonym.plus flags them so you can apply the minimisation rule before sharing.
What does the Consumer Duty add at renewal?
Principle 12 and PRIN 2A require firms to act to deliver good outcomes for retail customers, in force for open products since 31 July 2023. The disclosure and price fields are the evidence, so keep them and drop the identity.