Performance warning redaction is the removal of personal data from a capability or conduct notice. ERA 1996 s.98(2)(a) recognises capability as a potentially fair reason and s.98(4) asks whether the employer acted reasonably; the ACAS Code expects an improvement period and an appeal before a sanction bites. anonym.plus marks names and contacts on your device, so the notice stays clear while the worker is shielded.
When this applies
A warning names the worker, the manager, and metric targets. You strip those identifiers before the notice is used for analysis or training.
How anonym.plus handles it
- Open the notice in anonym.plus on your device.
- The app marks worker and manager names.
- Built-in OCR reads a scanned signed warning.
- Turn the alias map OFF for true anonymity.
- Swap or black out the confirmed identifiers.
- Save the clean copy locally.
What you need to provide
- The discipline notice (PDF, DOCX, or scan).
- An operator (Redact for analytics exports).
- Alias map turned OFF for true anonymisation.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | the worker → [SUBJECT] |
| Names | PERSON | the manager → [MANAGER] |
| Contact | EMAIL_ADDRESS | hr@example.co.uk → [EMAIL] |
| Dates | DATE_TIME | issued 5 June → [DATE] |
| Location | LOCATION | Newcastle site → [LOCATION] |
| Identifiers | UK_NINO | QQ 12 34 56 C → [NINO] |
Compliance achieved
- Keeps the capability reason ERA 1996 s.98(2)(a) recognises and the reasonableness test in s.98(4).
- Preserves the improvement-and-review trail the ACAS Code of Practice on Disciplinary and Grievance Procedures expects before a sanction.
- Retains the accompaniment record under Employment Relations Act 1999 s.10.
- Targets the anonymity bar in UK GDPR Recital 26 once the notice becomes a template, and applies storage limitation under Art. 5(1)(e) when it expires.
- Offline work keeps the warning off any server, with AES-256-GCM at rest.
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Limitations & cautions
Recital 26 treats data as anonymous only when no one can be singled out under the motivated-intruder test, and a rare role plus a metric can still point to one person. Redacting a copy for trend work does not shorten how long the live warning must be kept, and it does not cure a process that skipped the steps the ACAS Code sets out.
Frequently asked questions
How do I make a warning truly anonymous?
Turn the reversible alias map OFF and use Redact. Then check that no unique role or metric singles out a person, as Recital 26 requires.
Does the ACAS Code cover poor performance, not just misconduct?
Yes. The ACAS Code of Practice on Disciplinary and Grievance Procedures applies to capability as well as conduct, so keep the improvement period, the review, and the appeal visible in the record.
Is the notice uploaded?
No. The app runs locally, so the warning never reaches a cloud server.