Investor questionnaire redaction is the removal of personal data from an appropriateness or investor-status form. FCA COBS 10A sets the appropriateness test for non-advised MiFID business — asking whether the client has the knowledge and experience to understand the risks — with COBS 10 covering other business. Where the form certifies investor status instead, it usually rests on the Financial Promotion Order 2005 (SI 2005/1529) art. 48, for a certified high net worth individual, or art. 50A, for a self-certified sophisticated investor. The FCA's high-risk investment regime in PS22/10, in force from 1 February 2023, tightened the risk warnings and appropriateness journey around those forms. anonym.plus marks each identity field on your device, so the answers stay while the respondent goes.
When this applies
An appropriateness form pairs a respondent's identity with their trading experience, income and self-certification. An aggregation exercise, a product governance review or a compliance sample needs the answer distribution, not the respondent. You trim the identity before the batch is analysed.
How anonym.plus handles it
- Open the form in anonym.plus on your device.
- Local OCR reads scanned questionnaire and certificate pages.
- The tool flags name, NI number, income and contact data.
- Keep the experience answers, knowledge scores and status category.
- Swap or black out the marked items.
- Save the clean copy locally.
What you need to provide
- The questionnaire (PDF, DOCX, or scan).
- An operator (Replace keeps the answers readable).
- Optional batch for a whole survey wave, up to 20 files per run.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | respondent E. Coster → [RESPONDENT] |
| Identifiers | UK_NINO | QQ 88 19 88 A → [NINO] |
| Money | MONEY | income £72,000 → [INCOME] |
| Dates | DATE_TIME | born 1988 → [DOB] |
| Contact | EMAIL_ADDRESS | e.coster@example.co.uk → [EMAIL] |
| Location | LOCATION | home address → [ADDRESS] |
Compliance achieved
- FCA COBS 10A sets the appropriateness test for non-advised MiFID business — whether the client has the knowledge and experience to understand the risks — with COBS 10 covering other business; the answers are the evidence and can stay.
- An investor-status certificate usually relies on Financial Promotion Order 2005 (SI 2005/1529) art. 48 (certified high net worth individual) or art. 50A (self-certified sophisticated investor) — the category survives redaction; the signature block does not need to.
- The FCA's strengthened regime for high-risk investments in PS22/10, in force from 1 February 2023, tightened risk warnings, cooling-off and the appropriateness journey around these forms.
- Aggregating a survey wave is where re-identification bites: UK GDPR Recital 26 asks whether anyone could re-identify by reasonable means, so band the income and age answers as well as removing names.
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Limitations & cautions
An income band, an age and a postcode district together can single out a respondent even after direct identifiers are gone, and free-text answers carry more clues than tick boxes. The tool flags named items, not combinations. Review free-text responses before you aggregate.
Frequently asked questions
What does an appropriateness test measure?
Under COBS 10A, whether the client has the knowledge and experience to understand the risks of the product or service they are asking for on a non-advised basis. It is a narrower test than suitability under COBS 9A. Redaction leaves the knowledge and experience answers intact.
Can I keep the self-certification category?
Yes. Whether the respondent certified under FPO 2005 art. 48 or art. 50A is a category, not an identifier, and a governance review usually needs it. The name, signature, address and income figure are what get marked.
Is the form uploaded?
No. The application works offline, so respondent data stays on your device throughout the survey wave.