Sample-log de-identification is the removal of recipient and representative IDs from a distribution register. Free samples may only reach a prescriber on a signed, dated request, with an adequate system of control, under Part 14 of the Human Medicines Regulations 2012. anonym.plus runs locally and keeps the product, lot, and count for audit work.
When this applies
A distribution register names the prescriber who received samples and the representative who left them. An internal audit checks the volumes and the control system — the named prescriber is personal data all the same.
How anonym.plus handles it
- Load the register into anonym.plus on your device.
- It finds prescriber and rep names plus IDs.
- Dates and signature lines get flagged across the entry.
- Confirm the flags; the product and lot stay as non-IDs.
- Black out items for the audit, or swap them for analysis.
- Save the clean copy; the source stays on your machine.
What you need to provide
- The register (CSV, PDF, DOCX, or system export).
- A column map for the recipient and rep fields.
- An operator (Redact for audit copies).
Patient data entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Dr. Blackwood → [RECIPIENT] |
| Names | PERSON | field rep → [REP] |
| Dates | DATE_TIME | left 04/12 → [DATE] |
| Record IDs | ID | drop no. 55812 → [DROP_ID] |
| Location | LOCATION | GP Surgery, Leeds → [SITE] |
| Identifiers | NATIONAL_ID | GMC no. → [ID] |
Compliance achieved
- Free samples may only go to a prescriber on a signed, dated request and under an adequate system of control — Part 14 of the Human Medicines Regulations 2012.
- The ABPI Code of Practice adds limits on how many samples a prescriber may receive and how the record must be kept.
- A named prescriber and a GMC registration number are personal data under DPA 2018 s.3(2), even where no patient appears in the log.
- Offline processing avoids a cloud processor and any UK GDPR Art. 28 contract; working files are held under AES-256-GCM.
Anonymise sample distribution logs offline — see plans & start free →
Limitations & cautions
These registers are tabular. Check that the signature column is mapped, since a name there is easy to miss. The product and count stay as non-IDs. Do not redact the control record itself — Part 14 of the Human Medicines Regulations requires an adequate system of control, so clean only the copy you circulate.
Frequently asked questions
Are recipient prescriber names removed?
For the shared copy, yes. A named prescriber and a GMC number are personal data under DPA 2018 s.3(2), so most teams blind them for an audit. The tool can flag recipient and rep names together or apart.
Can I redact the statutory control record?
No. Part 14 of the Human Medicines Regulations 2012 requires an adequate system of control over samples, so the original record stays complete. De-identify an export instead.
Is the product kept?
Yes. The product, lot, and count stay, since they are not personal identifiers. The register is still useful for an audit.