Salary report anonymisation is the removal of identifiers so a pay file no longer points at a person. UK GDPR Recital 26 puts data outside the regulation only when nobody can identify anyone by means reasonably likely to be used. The ICO tests that with a motivated intruder. anonym.plus marks each name, reference, and figure on your device, so the analysis survives while no individual does.
When this applies
Pay analysis rarely stops inside HR. A quoted company with more than 250 UK employees publishes a CEO pay ratio against its 25th, 50th, and 75th percentile earners under the Companies (Miscellaneous Reporting) Regulations 2018. Boards ask for the working behind it. Equality Act 2010 s.77 also makes a pay-secrecy clause unenforceable where a colleague asks about pay to check for discrimination.
How anonym.plus handles it
- Open the table in anonym.plus on your device.
- The tool flags names, references, and pay figures.
- Local OCR reads a scanned page if present.
- Confirm the flags and keep band labels intact.
- Swap or black out the marked items.
- Save the anonymous file locally.
What you need to provide
- The file (XLSX, CSV, PDF, or scan).
- An operator (Replace keeps the table readable).
- Optional: turn the name map OFF for true anonymity.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | row Aisha Khan → [STAFF] |
| Financial | MONEY | £92,000 → [SALARY] |
| Identifiers | UK_NINO | NI number → [NINO] |
| Organization | ORGANIZATION | Acme HR → [ORG] |
| Dates | DATE_TIME | review 2026 → [DATE] |
| Location | LOCATION | office city → [SITE] |
Compliance achieved
- Aims at the anonymity standard in UK GDPR Recital 26, tested by the ICO's motivated intruder approach.
- Turn the name map off, because a retained key leaves the file pseudonymised under UK GDPR Art. 4(5), not anonymous.
- Reduces exposure to the re-identification offence in DPA 2018 s.171, which bites on de-identified personal data.
- Supports the working behind the CEO pay ratio in the Companies (Miscellaneous Reporting) Regulations 2018, for quoted companies above 250 UK employees.
- Leaves the pay discussion that Equality Act 2010 s.77 protects possible, since bands survive while names go.
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Limitations & cautions
Recital 26 is a high bar. A small team plus a band can still single someone out, so aggregate before you share and keep the map off. The tool removes named identifiers. It cannot judge whether a combination of surviving columns is unique.
Frequently asked questions
When is a pay file genuinely anonymous?
Only when no one can identify a person by means reasonably likely to be used. That is the UK GDPR Recital 26 test the ICO applies through a motivated intruder. Aggregate small groups and keep the reversible map off.
What is the difference between anonymous and pseudonymised here?
A retained key means the data is pseudonymised under UK GDPR Art. 4(5) and still personal data. Anonymous means no key exists at all, which is why the map switch matters.
Does anonymisation help with pay-ratio reporting?
It lets you circulate the workings. The published ratio is a company disclosure, so treat the anonymous file as the internal draft, not the statutory report.