Evidence anonymisation (redaction)

Patient and colleague confidentiality

In order to meet your responsibility to patient confidentiality standards in Good medical practice, you must check every page of your evidence for patient or sensitive data. This data must be redacted before you submit it as part of your application.

An example letter showing before and after redaction is applied.

 

Failure to anonymise your evidence

It’s your responsibility to make sure that your evidence is anonymised. We accept no responsibility for checking that all your evidence is anonymised. We won't anonymise any data on your behalf. It is likely to cause delays to your application if you don't anonymise your evidence.

If we identify personal information while we're checking your evidence, we’ll:

  • delete the file from your application and ask you to resubmit it once it’s been fully redacted
  • inform the relevant royal college or faculty that your application included personal data
  • ask you to provide updated training records and a reflection regarding data protection.

If you submit further evidence which hasn’t been anonymised at the stage we’re ready to send your application for evaluation, we’ll exclude these documents from your application.

If the evidence, when sent for evaluation, contains patient or sensitive data, your application will fail.

If you don’t follow these requirements, you may be in breach of the General Data Protection Regulation (GDPR) and the patient confidentiality standards in Good medical practice.  We may refer you to our Fitness to Practise directorate.

 

You must redact or remove:

1. All patient identifying details. This includes:

  • names (first and last)
  • nicknames
  • addresses, including street names and postcodes
  • contact details
  • NHS and all unique reference numbers
  • any weblink addresses or QR codes that link to a particular document or contain a unique reference number
  • reference numbers on letters
  • photos of patients (or eyes if close up on face).

Gender and Date of birth don’t need to be redacted. This information can be useful to the evaluators in assessing the range of patients seen by the applicant. This is not an exhaustive list.

2. Details of patients’ relatives and other members of the public not acting in a professional capacity

3. Details of colleagues that you’ve assessed, written a reference for, or who have been involved in a complaint. This includes:

  • names (first and last)
  • GMC numbers
  • contact details, such as phone numbers or email addresses
  • login codes and reference numbers of assessments
  • for evidence of a serious incident or a complaint, all doctors' names apart from your own must be redacted.

Please don’t redact colleague data from your other evidence such as your consultants who have assessed your WPBAs / attended Meetings / mentioned in letters or e-mails.

For a list of evidence which is likely to contain patient and colleague data, please see our Application and evidence guidance.

 

Redacting electronic evidence

Read through your evidence thoroughly to identify any patient or sensitive data. Redaction of sensitive data must be permanent. It must be impossible to retrieve the data from the document after your redaction.

We recommend you use PDF redaction software such as Adobe Acrobat to redact your evidence. Redaction software can be found through popular search engines. Please don’t redact your evidence through alternative means such as covering text with text boxes or similar. It is likely that the underlying text will still be selectable. Read the Adobe redaction guide for support with Adobe redaction functionality.

It is important to remember to ‘apply’ your redactions after you have selected them in your PDF editor. Your workplace may have training and IT support for redacting documentation.

After you have applied redaction check that:

  • you cannot copy and paste the data from below the redaction
  • you cannot move boxes or shapes in front of the data to reveal it
  • you cannot view the redacted data in any way.

Only submit your evidence after checking the redaction is permanent.

 

Checking your evidence files

Data may be present in other ways such as:

  • Spreadsheets (xls file) – you must check the whole workbook for data. Check any hidden columns and hidden worksheet data have been removed.
  • Embedded files / Links to files – this is where one file is accessible from inside another file. Remove any embedded files or links from evidence.

 

Redacting paper before scanning a document

Use a redaction pen or black crayon for redacting data on paper. This leaves a thick layer which is difficult to scan through. Do not use ballpoint pens / felt tip pens / correction fluid. These methods are more likely to reveal data after drying on the paper.