Bordereau redaction is the removal of personal identifiers from a ceded-risk schedule. A bordereau often crosses a border, and UK GDPR Art. 44 bars a transfer that undermines the regime, with Art. 46 setting the safeguards where no adequacy decision applies. The ICO's International Data Transfer Agreement and its Addendum to the EU clauses have been available for that purpose since 21 March 2022. Strip the identifiers and Recital 26 may take the schedule outside the rules altogether.
When this applies
A ceded-risk schedule lists each line with names and amounts. The reinsurer prices the portfolio, not the individuals. You strip the identifiers before the table goes out, which is also the cleanest answer to a transfer question under Art. 44.
How anonym.plus handles it
- Open the schedule in anonym.plus on your device.
- The tool flags names, IDs, and contacts per row.
- Local OCR reads any scanned source sheet.
- Turn the alias map OFF for true anonymity.
- Swap or black out the confirmed identifiers.
- Save the clean table locally.
What you need to provide
- The schedule (CSV exported to PDF, DOCX, or TXT).
- An operator (Redact suits a shared table).
- The alias map turned OFF so no link survives.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | insured per row → [SUBJECT] |
| Identifiers | UK_NINO | national insurance no → [NINO] |
| Financial | MONEY | ceded sum £120,000 → [AMOUNT] |
| Organisation | ORGANIZATION | cedent name → [CEDENT] |
| Dates | DATE_TIME | inception 2024 → [DATE] |
| Location | LOCATION | risk region → [REGION] |
Compliance achieved
- Anonymous data sits outside UK GDPR altogether under Recital 26, so a stripped schedule raises no transfer question at all.
- Where personal data must travel, UK GDPR Art. 44 sets the general principle and Art. 46 the safeguards; the ICO's International Data Transfer Agreement and Addendum have been available since 21 March 2022.
- A delegated-authority partner handling the same rows is usually a processor, so UK GDPR Art. 28 terms apply to them as well.
- Turning the alias map off removes any re-link route; the whole run stays on your machine.
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Limitations & cautions
Recital 26 treats data as anonymous only if no one can re-identify a person. A rare risk in a small region can still single someone out, and that risk grows once the schedule sits next to the reinsurer's own data. Check outliers before you cede the table.
Frequently asked questions
Does UK GDPR apply to a ceded schedule?
Yes, wherever it holds personal data. Recital 26 only exempts data that cannot re-identify anyone, so strip the identifiers first — that also removes the Art. 44 transfer question.
What if some personal data must go abroad?
Then you need an Art. 46 safeguard unless an adequacy decision covers the destination. The ICO's International Data Transfer Agreement and the Addendum to the EU standard clauses have been available since 21 March 2022.
Why turn off the alias map?
An alias map can re-link a row to a person. For true anonymity under Recital 26, leave it off so no reverse path remains.