Response de-identification is the removal of personal identifiers from a digital health questionnaire. Health answers are special category data under UK GDPR Art. 9(1). Where the work is research rather than service evaluation, Art. 9(2)(j) is the usual gateway and DPA 2018 section 19 adds safeguards: the processing must not be likely to cause substantial damage or distress, and it must not support measures or decisions about a particular person. anonym.plus runs offline and keeps the scored answers.
When this applies
A patient-reported outcome measure collects scores, plus the respondent's name, email, and free-text comments. NHS England runs a national PROMs programme on much the same pattern. Analysis needs the scores, so the identifying answers come out first.
How anonym.plus handles it
- Open the answers in anonym.plus on your device.
- It finds names, emails, and clues in the comments.
- Scored items and rating scales stay in place.
- Swap or black out the confirmed personal parts.
- Save the clean results on your device.
What you need to provide
- The answers (CSV, JSON, PDF, or DOCX).
- An operator: Replace keeps the rows readable.
- Optional column map for identifier fields.
Patient data entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | respondent name → [RESPONDENT] |
| Contact | EMAIL_ADDRESS | reply email → [EMAIL] |
| Free text | PERSON | “my son Eli” → [RELATIVE] |
| Dates | DATE_TIME | submit date → [DATE] |
| Identifiers | ID | respondent code → [ID] |
| Free text | LOCATION | “here in Sheffield” → [PLACE] |
Compliance achieved
- Strips health answers that are special category data under UK GDPR Art. 9(1).
- Research use runs on the gateway in UK GDPR Art. 9(2)(j).
- Applies the research safeguards in DPA 2018 section 19, including no measures or decisions about a particular person.
- Fits study governance under the UK Policy Framework for Health and Social Care Research (2017), with HRA approval and REC review where needed.
- Matches the outcome-measure pattern used by the NHS England PROMs programme.
- Catches clues inside free-text comments, not just identifier columns.
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Limitations & cautions
Open comment boxes are the hard part, because a respondent may name a place, a job, or a relative. Review those boxes as you would a clinical note. A rare answer combination can re-identify even after the direct identifiers are gone.
Frequently asked questions
Is my survey research or service evaluation?
The distinction drives the governance. Research generally needs HRA approval and, for NHS patients, review by a research ethics committee under the UK Policy Framework for Health and Social Care Research. Service evaluation of your own care usually does not. Anonymising the responses helps in either case, but it does not settle which route you are on.
What does DPA 2018 section 19 require?
It sets safeguards for processing carried out for research or statistical purposes. The processing must not be likely to cause substantial damage or substantial distress, and it must not be used for measures or decisions about a particular individual. Removing identifiers is the most direct way to meet the second limb.
Can answers stay linkable across waves?
Yes. A steady code map gives each respondent one alias for a longitudinal study. Holding that map keeps the file pseudonymous, so store it separately and treat it as personal data.