Enrolment log de-identification is the removal of participant identifiers under UK GDPR Art. 9 & DPA 2018. anonym.plus does this on your own device. The list still shows counts, but not who each person is.
When this applies
A coordinator must share enrolment numbers for a status update. The sheet links each code to a real name, a date of birth, and a phone.
How anonym.plus handles it
- Open the file (XLSX, CSV, or PDF) in anonym.plus on your device.
- The tool scans the rows for names, dates, and contact fields.
- Local OCR handles any scanned paper page you add.
- Confirm the flagged name, birth date, and phone columns.
- Swap names for codes, or black out the whole column.
- Save the clean copy. The original stays on your machine.
What you need to provide
- The file (XLSX, CSV, PDF, or scan).
- An operator: Redact a column, or Replace names with codes.
- Optional: a code map if you must re-link rows later.
Patient data entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Grace Okafor → [SUBJECT_3] |
| Birth date | DATE_TIME | DOB 12/07/1958 → [DOB] |
| Contact | PHONE_NUMBER | +44 20 7946 0164 → [PHONE] |
| Address | LOCATION | 44 Oak Road, Sheffield → [ADDRESS] |
| NHS number | MEDICAL_RECORD_NUMBER | NHS 485 777 3310 → [NHS_NO] |
| Local ID | ID | MRN 778210 → [LOCAL_ID] |
Compliance achieved
- The subject identification code list and enrolment log are essential documents under ICH E6(R2) §8.3 — they must exist, and they must stay confidential.
- This sheet is the re-identification key, so it remains personal data even when every other trial file is coded — UK GDPR Art. 4(5).
- NHS numbers and contact details engage UK GDPR Art. 9(1) and the common law duty of confidentiality owed to each participant.
- Deliberate re-identification of a de-identified dataset by a recipient is a criminal offence under DPA 2018 s.171.
- Runs offline — no cloud upload, no data-processor contract; working copies stay under AES-256-GCM.
Anonymise subject enrolment logs offline — see plans & start free →
Limitations & cautions
The ICO Anonymisation Code requires you to consider all means reasonably likely to identify a participant. The tool removes direct identifiers. A small site with one rare condition can still narrow things down; apply the motivated-intruder test before sharing widely.
Frequently asked questions
What is a subject enrolment log?
It is the essential document under ICH E6(R2) §8.3 that maps each trial code to a real person, with a name, birth date and contact. It is the re-identification key, so under UK GDPR Art. 4(5) every coded file elsewhere stays personal data for as long as this sheet exists. Deliberate re-identification by a recipient is an offence under DPA 2018 s.171.
Is a data-processor contract needed?
No. anonym.plus runs on your own device with no cloud step. No outside party sees the rows, so no processor agreement is triggered.
Can I keep the codes but drop the names?
Yes. Redact the name and contact columns and leave the trial codes. The shared copy then shows counts without naming anyone.