Exit interview redaction is the removal of personal identifiers from a leaver's feedback notes. UK GDPR Recital 26 puts data that no longer points to a person outside the rules, and the ICO applies a motivated-intruder test to decide whether that bar is met. anonym.plus marks each name and detail on your own machine, so the candid feedback survives while the person behind it is hidden.
When this applies
A leaver often says on the way out what they never said in post. Where that remark tends to show wrongdoing, it can be a qualifying disclosure under Part IVA of the Employment Rights Act 1996, inserted by the Public Interest Disclosure Act 1998, and s.47B then protects the worker from detriment for making it. Naming the discloser in a summary that reaches leadership is how that detriment starts. The notes also name managers and colleagues, whose own rights Art. 15(4) weighs if the file is ever disclosed.
How anonym.plus handles it
- Open the notes in anonym.plus on your workstation.
- Local OCR reads a scanned, hand-written page.
- The tool flags the leaver, managers, and colleagues named.
- Confirm each flag and keep the themes intact.
- Replace each name with a steady label, or black it out.
- Save the clean summary locally — it never leaves the device.
What you need to provide
- The interview notes (PDF, DOCX, or TXT).
- An operator: Replace (swap), Redact (black out), or Mask (partial).
- Optional: a name map, kept off for true anonymity.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Sophie Turner → [LEAVER] |
| Names | PERSON | line manager named → [MANAGER] |
| Contact | EMAIL_ADDRESS | s.turner@example.co.uk → [EMAIL] |
| Contact | PHONE_NUMBER | +44 20 7946 0101 → [PHONE] |
| Dates | DATE_TIME | last day 14/03 → [DATE] |
| Organisation | ORGANIZATION | former team name → [TEAM] |
Compliance achieved
- Works towards the anonymity bar in UK GDPR Recital 26, which the ICO tests with its motivated-intruder approach.
- Keeps a leaver who made a qualifying disclosure under ERA 1996 Part IVA (ss.43A-43B, inserted by the Public Interest Disclosure Act 1998) out of the circulated summary.
- Cuts the detriment risk ERA 1996 s.47B catches, which runs from the moment colleagues learn who spoke.
- Serves data minimisation under UK GDPR Art. 5(1)(c) — a themes summary needs the finding, not the names.
- Protects the managers and colleagues named, whose rights Art. 15(4) weighs on any later disclosure.
- Working copies are kept safe with AES-256-GCM at rest.
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Limitations & cautions
Frank feedback can point to a person through a rare role or a single well-known event, not just a name. The tool flags named items. Read the free-text comments yourself for indirect clues, and remember a protected disclosure keeps its protection whether or not the notes name the discloser.
Frequently asked questions
Does Recital 26 mean redacted notes fall outside UK GDPR?
Only if re-identification is no longer reasonably possible, which the ICO tests as a motivated intruder would. anonym.plus removes the named identifiers; you must also check that a unique remark cannot single someone out.
What if the interview contains a whistleblowing concern?
Treat it as a possible qualifying disclosure under Part IVA of the ERA 1996. Redacting who said it in the circulated summary lowers the detriment risk s.47B catches, but the concern itself still has to be investigated.
Is the feedback uploaded anywhere?
No. The desktop app runs on your machine with no cloud step, so the notes stay private.