Performance report redaction is the removal of personal data from a returns summary. Sent to a client, the summary is a report under FCA COBS 16A. Shown to anyone else as a track record, it becomes a financial promotion: FSMA 2000 s.21 restricts who may communicate an invitation or inducement to engage in investment activity, COBS 4.2.1R requires every communication to be fair, clear and not misleading, and COBS 4.6 sets the rules for past, simulated past and future performance. A real client's numbers cannot be used as a sample while they still name that client. anonym.plus marks each identifier on your device, so the figures stay while the holder goes.
When this applies
A returns summary pairs an owner's name with balances, gains and a benchmark comparison. A pitch deck, a case study or a website sample needs the performance, not the person. You strip the identity first, then apply the promotion rules to whatever remains.
How anonym.plus handles it
- Open the summary in anonym.plus on your device.
- Local OCR reads scanned chart and appendix pages.
- The tool flags names, account numbers, NI numbers and contacts.
- Keep the return percentages, periods and benchmark names.
- Swap or black out the marked items.
- Save the clean copy locally.
What you need to provide
- The returns summary (PDF, DOCX, or scan).
- An operator (Replace keeps the figures readable).
- Optional allow-list for benchmark and index names.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | owner T. Park → [HOLDER] |
| Financial | UK_BANK_NUMBER | acct 5521 → [ACCOUNT] |
| Money | MONEY | gain £84,300 → [GAIN] |
| Identifiers | UK_NINO | QQ 20 46 71 B → [NINO] |
| Dates | DATE_TIME | period 2024 → [PERIOD] |
| Contact | EMAIL_ADDRESS | t.park@example.co.uk → [EMAIL] |
Compliance achieved
- Once a client's numbers are shown to anyone else as a track record, FSMA 2000 s.21 restricts the communication of an invitation or inducement to engage in investment activity — the promotion must be made or approved by an authorised person.
- FCA COBS 4.2.1R requires the communication to be fair, clear and not misleading, and COBS 4.6 governs past, simulated past and future performance — including that past performance must not be the most prominent feature.
- Sent to the client instead, the same summary is a report under COBS 16A, which a portfolio manager issues at least quarterly; redaction never replaces the report the client actually receives.
- For a public sample, aim at the UK GDPR Recital 26 standard: no reasonable means of re-identification, which means banding standout figures as well as removing names.
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Limitations & cautions
A standout return in a named period can point to one portfolio even with the holder removed, and the tool cannot judge whether a promotion is fair, clear and not misleading under COBS 4.2.1R. Anonymise, then have the communication signed off before it is used publicly.
Frequently asked questions
Can I reuse a real client's returns as a marketing sample?
Only after the identity is stripped, and only within the promotion rules. Showing a track record to attract business engages FSMA 2000 s.21, COBS 4.2.1R and the past performance rules in COBS 4.6. Redaction handles the personal data; the sign-off handles the promotion.
Will the benchmarks survive?
Yes. Allow-list benchmark and index names before the run. Only personal identifiers are marked, so the comparison and the periods still read.
Is the report sent anywhere?
No. The application works offline, so returns data stays on your machine while you prepare the sample.