Equal pay analysis de-identification is the removal of personal identifiers from a remuneration study. Equality Act 2010 s.65 defines equal work as like work, work rated as equivalent, or work of equal value. Section 66 implies a sex equality clause into the contract of anyone doing it. anonym.plus marks each name and figure on your device, so the gap model still runs.
When this applies
A study of this kind is discoverable. Where an employer loses a claim under those provisions, the Equality Act 2010 (Equal Pay Audits) Regulations 2014 let a tribunal order an audit and require it to be published. Separately, an employer with 250 or more employees takes a 5 April snapshot and publishes six gender pay gap measures within twelve months under the 2017 Regulations.
How anonym.plus handles it
- Open the sheet in anonym.plus on your device.
- The tool flags names, references, and wage figures.
- Local OCR reads a scanned table if present.
- Confirm the flags and keep job-grade columns.
- Swap or black out the marked items.
- Save the anonymous file locally.
What you need to provide
- The sheet (XLSX, CSV, PDF, or scan).
- An operator (Replace keeps the grid readable).
- Optional: turn the name map OFF for true anonymity.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | row J. Coleman → [STAFF_1] |
| Financial | MONEY | wage £71,000 → [WAGE] |
| Identifiers | UK_NINO | NI number → [NINO] |
| Organization | ORGANIZATION | Eng unit → [TEAM] |
| Dates | DATE_TIME | hire 2021 → [DATE] |
| Location | LOCATION | site label → [SITE] |
Compliance achieved
- Tests the three routes in Equality Act 2010 s.65: like work, work rated as equivalent, and work of equal value.
- Supports the sex equality clause that Equality Act 2010 s.66 implies into a contract of employment.
- Preserves the evidence for a material factor defence under Equality Act 2010 s.69.
- Prepares the six measures the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 require from a 5 April snapshot.
- Anticipates an audit a tribunal may order under the Equality Act 2010 (Equal Pay Audits) Regulations 2014.
- Keeps job grades and hours in place, so the gap model still runs after names go.
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Limitations & cautions
A thin grade combined with a protected characteristic re-identifies a person even after names go, so aggregate small cells first. The tool removes identifiers. It does not decide whether two jobs rank as equivalent, which is a s.65 judgement and often an expert one.
Frequently asked questions
What counts as equal work under the Equality Act 2010?
Section 65 gives three routes: like work, work rated as equivalent under a job evaluation study, and work of equal value. A de-identified sheet lets you test all three without naming people.
Who has to publish gender pay gap figures?
Employers with 250 or more employees. The 2017 Regulations set a 5 April snapshot for private and voluntary employers, and six published measures within twelve months.
What is a material factor defence?
Under Equality Act 2010 s.69 an employer can defend a difference in terms by showing a genuine factor that has nothing to do with sex. The contemporaneous study is where that reasoning has to be visible.