Register anonymisation is the removal of details that make each member identified or identifiable under UK GDPR Art. 4(1). CA 2006 s.113 requires the statutory register to hold each member's name and address, and s.116 gives members and others a right to inspect it for a proper purpose. anonym.plus cleans the copy you circulate, on a local device, while the register itself stays as the Act requires.
When this applies
A members list names every shareholder with their address and holding. Under s.117 the company has five working days to comply with an inspection request or ask the court to rule the purpose improper. A bidder's data room copy needs none of that detail, so make it anonymous first.
How anonym.plus handles it
- Open the list in anonym.plus on a local device.
- It spots member names, addresses, and ID numbers.
- Swap each one for a non-reversible label for true anonymity.
- Keep no re-link key if you want it outside scope.
- Save the clean list on your device.
What you need to provide
- The list (XLSX, CSV, PDF, or Companies House export).
- Replace, with the reversible map turned off.
- Optional language setting for cross-border members.
PII entity types detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | Mr Hargreaves → [MEMBER] |
| Location | LOCATION | 7 Mill Lane, York → [ADDRESS] |
| Identifiers | NATIONAL_ID | NINO A123456 → [ID] |
| Contact | EMAIL_ADDRESS | hargreaves@mail.co.uk → [EMAIL] |
| Finance | IBAN_CODE | dividend account → [ACCOUNT] |
| Org | ORGANIZATION | nominee fund → [ENTITY] |
Compliance achieved
- Removes what makes a member identifiable under UK GDPR Art. 4(1).
- Leaves the statutory particulars CA 2006 s.113 requires untouched.
- Cleans the copy shared outside a CA 2006 s.116 proper-purpose request.
- True anonymity puts the shared list beyond UK GDPR by Recital 26.
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Limitations & cautions
You cannot anonymise the statutory register itself — s.113 fixes what it must contain, and s.116 governs who may see it. A holding size also acts as a quasi-identifier: a lone 25% stake may point to one member after the name goes. If you keep a reversible map, the list is pseudonymous, not anonymous.
Frequently asked questions
Anonymous or pseudonymous — what is the difference?
Pseudonymous output keeps a key that can re-link it, so it stays personal data. Anonymous output drops that key for good. Only then does Recital 26 apply.
Can I anonymise the register the company must keep?
No. CA 2006 s.113 sets the particulars the statutory register must hold, and s.116 gives a right to inspect it. This work cleans the extract you circulate to bidders, not the register of members itself.
What makes a member identifiable under Art. 4(1)?
Any detail that singles out a person — a name, an address, an ID, or even a unique holding. All such clues must go for true anonymity.