Supplier-onboarding redaction is the removal of vendor PII from an intake sheet. Those sheets exist because Bribery Act 2010 s.7(2) gives an organisation a defence only where it had adequate procedures, and supplier due diligence is one of them. Criminal Finances Act 2017 s.45 works the same way, with reasonable prevention procedures. So the form collects real personal data and is then shared internally.
When this applies
An intake sheet packs contact names, bank fields, and a VAT number into fixed boxes. Larger buyers add a Modern Slavery Act 2015 s.54 question, which applies to organisations with a turnover of £36 million or more. To reuse the template or send the pack for audit, you clear the personal fields and keep the category answers.
How anonym.plus handles it
- Load the sheet into anonym.plus on your device.
- The tool finds contact, tax, and bank fields.
- It flags the signatory and any personal email.
- Confirm the flags and keep the category fields.
- Swap or black out the confirmed data.
- Save the clean copy on your machine.
What you need to provide
- The intake sheet (PDF, DOCX, or scan).
- A field map for known ID columns.
- An operator (Redact for slim audit copies).
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | contact name → [CONTACT] |
| Banking | IBAN_CODE | bank field → [IBAN] |
| Identifiers | NATIONAL_ID | VAT/tax no. → [TAX_ID] |
| Contact | EMAIL_ADDRESS | ap@supplier.co.uk → [EMAIL] |
| Contact | PHONE_NUMBER | supplier tel → [PHONE] |
| Company | ORGANIZATION | supplier name → [SUPPLIER] |
Compliance achieved
- Supports the adequate-procedures defence in Bribery Act 2010 s.7(2) by keeping due-diligence data on your own device.
- Matches the reasonable-prevention-procedures standard in Criminal Finances Act 2017 s.45.
- Keeps the Modern Slavery Act 2015 s.54 answers while clearing contacts and bank fields.
- A field map catches known ID columns at once.
- On-device AES-256-GCM guards the working files.
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Limitations & cautions
Fixed layouts vary by firm. Check that your custom fields are mapped, so nothing slips by. A small counterparty's VAT number plus a category can still trace back, so review the result.
Frequently asked questions
Why does an onboarding form hold so much personal data?
Because the checks behind it are legal defences. Bribery Act 2010 s.7(2) protects an organisation only where it had adequate procedures, and Criminal Finances Act 2017 s.45 turns on reasonable prevention procedures. Both push buyers to collect named contacts, ownership details, and bank data up front.
Are bank details removed?
Yes. IBAN, account, and sort-code fields are flagged along with the contacts. Those are the fields most often reused in payment-diversion fraud, so they rarely belong in a shared copy.
Can I keep the vendor category and the modern slavery answers?
Yes. Non-identifying category and compliance answers can stay via an allow-list while the personal data goes. The Modern Slavery Act 2015 s.54 statement applies to organisations with turnover of £36 million or more, and its answers are about the business, not a person.