Application redaction is the removal of personal data from a new-client opening form. Opening the arrangement engages regulated activities under the Regulated Activities Order 2001 (SI 2001/544) — art. 37 for managing investments and art. 40 for safeguarding and administering them. The same form carries the identity evidence required by MLR 2017 regs. 27 and 28, the categorisation the firm records under FCA COBS 3.4, and, for a stocks-and-shares ISA, the declaration required by the Individual Savings Account Regulations 1998 (SI 1998/1870). UK GDPR Art. 13 governs what you told the applicant at collection. anonym.plus marks each field on your device, so the form's structure stays while the data goes.
When this applies
A new-client pack gathers the applicant's identity, National Insurance number, funding details and tax residence in one place. A back-office vendor, an onboarding auditor or a platform migration team needs the structure, not the person. You trim the identifiers before the pack travels, and the signed original stays in the firm's own file as the MLR 2017 verification record.
How anonym.plus handles it
- Open the pack in anonym.plus on your device.
- Local OCR reads the scanned, signed declaration page.
- The tool flags name, NI number, date of birth and contact fields.
- Confirm each flag and keep the product and wrapper codes.
- Swap or black out the marked items.
- Save the clean copy locally, with the original untouched.
What you need to provide
- The signed pack (PDF, DOCX, or scan).
- An operator: Replace, Redact, or Mask.
- Optional alias map if you must re-link the applicant later.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Marcus Lind → [APPLICANT] |
| Identifiers | UK_NINO | QQ 41 29 08 B → [NINO] |
| Financial | UK_BANK_NUMBER | funding acct → [ACCOUNT] |
| Dates | DATE_TIME | DOB 04/12/1982 → [DOB] |
| Contact | PHONE_NUMBER | +44 7700 900147 → [PHONE] |
| Location | LOCATION | home address → [ADDRESS] |
Compliance achieved
- The arrangement engages RAO 2001 art. 37 (managing investments) and art. 40 (safeguarding and administering investments), so the signed pack is a permission-critical record — redact a copy, never the original.
- Identity evidence on the form exists because of MLR 2017 regs. 27-28, which require verification from a reliable, independent source; reg. 40 requires the record to be kept for five years after the relationship ends.
- FCA COBS 3.4 makes the applicant a retail client by default, and an ISA declaration answers to the ISA Regulations 1998 (SI 1998/1870) and its £20,000 annual subscription limit, unchanged since 6 April 2017.
- UK GDPR Art. 13 governs what the applicant was told at collection; offline redaction keeps the onward copy inside the boundary you described.
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Limitations & cautions
An intake pack stacks many identifiers close together, and a faint scan leans on OCR, where a digit in a sort code or an NI number can be misread. The tool does not decide whether a field is still needed under the MLR 2017. Check the flags on image pages before you export.
Frequently asked questions
Which fields get flagged on an investment account application?
Name, National Insurance number, date of birth, address, funding sort code and account number, and contact details. These are the fields MLR 2017 reg. 28 requires you to verify, so they are also the fields most worth removing from a shared copy.
Can I re-link the applicant later?
Yes, if you keep the optional alias map. Turn it off when you need true anonymity — a stored map means the data is pseudonymised under UK GDPR Art. 4(5), not anonymous, and it stays in scope.
Is the form uploaded for processing?
No. anonym.plus is a fully offline desktop tool, so the signed application never leaves your device.