Headcount anonymisation is the removal of personal identifiers from a staffing count. UK GDPR Recital 26 puts truly anonymous data outside the rules, and the ICO applies a motivated-intruder test to decide whether that bar is met. anonym.plus marks names and IDs on your device, so the totals stay usable while the people behind small cells are protected.
When this applies
The aggregate is the point. Companies Act 2006 s.411 requires the notes to a company's accounts to disclose the average number of persons employed, and s.414C(8)(c) requires a quoted company's strategic report to break down the number of directors, senior managers, and other employees of each sex. Neither needs a row per person, yet the export they are built from carries exactly that.
How anonym.plus handles it
- Open the export in anonym.plus on your device.
- The tool flags named staff rows and IDs.
- Local OCR reads a scanned summary page.
- Keep the team totals and period labels.
- Replace each identifier with a steady label.
- Save the clean summary locally.
What you need to provide
- The headcount export (CSV, XLSX export, PDF).
- An operator (Replace keeps the tables aligned).
- Optional allow-list for team and period labels.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | staff row → [WORKER] |
| Identifiers | NATIONAL_ID | staff no. 20911 → [STAFF_ID] |
| Organisation | ORGANIZATION | team name → [TEAM] |
| NRP | NRP | job title → [TITLE] |
| Dates | DATE_TIME | period Q2 → [PERIOD] |
| Contact | EMAIL_ADDRESS | work email → [EMAIL] |
Compliance achieved
- Works towards the anonymity bar in UK GDPR Recital 26, which the ICO tests with its motivated-intruder approach.
- Keeps the average employee numbers Companies Act 2006 s.411 requires in the notes to the accounts.
- Preserves the sex breakdown a quoted company's strategic report needs under Companies Act 2006 s.414C(8)(c).
- Names the halfway house honestly: a kept map is Art. 4(5) pseudonymisation, and stays personal data.
- Reduces exposure to the re-identification offence in DPA 2018 s.171.
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Limitations & cautions
A count is aggregate, yet a team of one re-identifies that worker, and a team of two lets each member work out the other. Band or suppress small teams before you circulate the summary. The tool removes named rows; it cannot judge which cells are too thin.
Frequently asked questions
Is a headcount total automatically anonymous?
No. A team of one re-identifies that person, and a team of two lets each member deduce the other. Review small cells and suppress or band them before sharing.
Which figures does company law actually need?
Companies Act 2006 s.411 needs the average number employed in the notes to the accounts, and s.414C(8)(c) needs the sex breakdown of directors, senior managers, and employees in a quoted company's strategic report. Both are aggregates.
Is the export uploaded?
No. The app runs offline, so the set stays on your device.