Disability claim anonymisation is the removal of personal data from a claim file, which is health data under UK GDPR Art. 9. Many claimants under an income-protection or critical-illness policy meet the FCA's definition of a vulnerable customer in its FG21/1 guidance, which asks the insurer to take extra care in how it handles the claim. The policy's own definition of disability is often measured against how Equality Act 2010 s.6 defines the term, even though that Act's own duties govern discrimination rather than insurance claims directly. anonym.plus does this on your device and keeps the medical evidence the assessment rests on.
When this applies
A disability file is special-category health data under Art. 9 and the claimant may also be a vulnerable customer under the FCA's FG21/1 guidance. Make it anonymous and you remove the burden of a lawful basis for study or training, while the medical evidence stays.
How anonym.plus handles it
- Open the file in anonym.plus on your device.
- It finds the claimant, the assessor, and contacts.
- Dates and ID numbers get flagged across the pages.
- Swap each one with the re-link key turned off.
- Confirm no key is left, then keep the evidence.
- Save the anonymous file on your machine.
What you need to provide
- The claim file (PDF, DOCX, or export).
- Replace with the re-link key off for full anonymity.
- Optional language setting for the assessment.
Patient data entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Claimant H. Berg → [CLAIMANT] |
| Assessor | PERSON | Dr Lund → [ASSESSOR] |
| NI number | UK_NINO | QQ 12 34 56 C → [ID] |
| Dates | DATE_TIME | Onset 2024 → [DATE] |
| Address | LOCATION | Home address → [ADDRESS] |
| Phone | PHONE_NUMBER | +44 7700 900170 → [PHONE] |
Compliance achieved
- Strips UK GDPR Art. 9 health identifiers from the file.
- Reduces the risk the FCA's FG21/1 vulnerable-customer guidance asks insurers to manage.
- Notes the disability definition in Equality Act 2010 s.6 that many policies borrow, without treating the Act's own discrimination duties as binding on the insurer's claims decision.
- True anonymity puts the result outside scope by UK GDPR Recital 26.
- Working copies are guarded by AES-256-GCM.
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Limitations & cautions
True anonymity is a high bar under the ICO motivated-intruder test. A rare condition plus a place and an onset date can re-identify even after direct IDs go. If you keep a re-link key, the result is pseudonymous, not anonymous, and stays in scope.
Frequently asked questions
Why is a disability file special under UK GDPR?
It is health data under Art. 9, so it needs a lawful basis to use, and the claimant will often also be a vulnerable customer under the FCA's FG21/1 guidance. Making the file anonymous removes the need for a lawful basis for any second use, though the FCA guidance still shapes how the original claim itself is handled.
Does the medical evidence stay?
Yes. The clinical findings stay exactly as recorded. Only personal IDs like the claimant and assessor names go.
How does the Equality Act 2010 relate to a disability claim?
The Act's own definition of disability in s.6 is often the yardstick a policy's disability benefit trigger is compared against, even though the Act's discrimination duties do not themselves govern how an insurer assesses the claim. That definitional overlap is background context, not a rule this tool enforces.