Log anonymisation is the removal of personal detail from the telemetry a connected medical device records. The readings are health data under UK GDPR Art. 9(1). The device itself is regulated by the MHRA under the Medical Devices Regulations 2002, which require adverse incidents to be reported, so the raw log has a safety role as well as an engineering one. DCB0129 covers clinical risk in manufacturing health IT and DCB0160 covers deploying it. anonym.plus works on a local machine and keeps the telemetry usable.
When this applies
An infusion pump or monitor writes events tagged with the patient, a serial number, and a network address. Fault analysis needs the event sequence, not the patient. Keep the untouched log for any MHRA report and anonymise the engineering copy.
How anonym.plus handles it
- Open the telemetry in anonym.plus on a local machine.
- It finds the patient key, serial, and network address.
- Event codes and sensor values stay in place.
- Swap the personal parts with the map switched off.
- Save the anonymous file on your machine.
What you need to provide
- The telemetry (CSV, JSON, or a raw dump).
- Replace with the re-link map off for anonymity.
- Optional column map for patient and serial fields.
Patient data entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | patient tag → [PATIENT] |
| Identifiers | ID | serial 22F-0931 → [SERIAL] |
| Network | IP_ADDRESS | 10.0.0.42 → [IP] |
| Identifiers | ID | MAC address → [MAC] |
| Dates | DATE_TIME | event time → shifted [TIME] |
| Location | LOCATION | ward tag → [PLACE] |
Compliance achieved
- Strips readings that are special category health data under UK GDPR Art. 9(1).
- Leaves the raw log intact for adverse incident reporting to the MHRA under the Medical Devices Regulations 2002 (SI 2002/618).
- Fits the manufacturer's clinical risk file under DCB0129 and the deploying organisation's under DCB0160.
- Both standards are issued under section 250 of the Health and Social Care Act 2012.
- Keeping telemetry on-site supports the NHS Data Security and Protection Toolkit.
- Health and adult social care information standards also feature in the Data (Use and Access) Act 2025, which received Royal Assent on 19 June 2025.
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Limitations & cautions
A serial or MAC address is unique, so it must go for true anonymity. A rare event sequence at a known site can still narrow identity once the tags are gone. Shift the timestamps and keep no re-link key.
Frequently asked questions
Why treat a serial or MAC address as personal data?
Each one maps to one device, and a device is usually assigned to one patient. That link is what UK GDPR looks at, so the identifier counts as personal data even though it names nobody. The tool flags and swaps both.
Should I anonymise a log before reporting a device fault?
No. Adverse incident reports to the MHRA under the Medical Devices Regulations 2002 rely on the raw evidence, and stripping fields first can destroy the sequence an investigator needs. Report from the original, and anonymise the copy you use for engineering analysis or supplier discussions.
Do the sensor values survive?
Yes. Event codes and readings remain in place, so fault analysis runs normally while the identifying tags are gone.