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Use case · Public sector · Case files

Administrative case files: give access without exposing third parties

Anonimatum Team

In short

People involved in a case can usually see their file, and courts receive the record, but case files are full of other people's data. The key is removing or pseudonymising it consistently across every document.

A case file is not one document but dozens: a complaint, inspection notes, officer reports, witness statements, photographs, letters and the final decision. Each mentions different people, and often the same person under different names: “Mr John Smith”, “Mr Smith”, “the complainant”.

When the person involved asks for a copy, when a tribunal needs the bundle or when an appeal goes to court, the challenge is not only to hide data but to do it the same way across every document, without a forgotten name in appendix 14 and without one version contradicting another.

United Kingdom: subject access and the rights of others

In the UK there is no single administrative procedure code; access to a case file usually comes through the right of access under the UK GDPR. When the file also contains information about other people, the Data Protection Act 2018 (Schedule 2, Part 3, “protection of the rights of others”) means you do not have to disclose it unless the third party consents or it is reasonable to disclose without consent.

The ICO guidance describes the balancing exercise: first ask whether you can comply without revealing the other person's identity, then consider consent, then weigh factors such as confidentiality, the significance of the information to the requester and whether they already know it. Staff acting in a professional role are more likely to be disclosed than private individuals. And redaction must be thorough, because people can be identifiable from context even when their name is removed.

When proceedings start, courts and tribunals operate their own disclosure rules and can order fuller access, often with confidentiality safeguards. Requests from people who are not parties fall under FOIA, covered in our page on FOI redaction.

United States: the Privacy Act and the administrative record

Individuals can request records about themselves held in federal agency systems of records under the Privacy Act of 1974. In judicial review of agency action, the agency files the administrative record with the court. Court filings are subject to the privacy protection rule of the Federal Rules of Civil Procedure (Rule 5.2), which limits Social Security and financial account numbers to the last four digits, birth dates to the year and minors to their initials, unless an exception applies.

One case file, several audiences

How third-party data is usually handled depending on the recipient
RecipientLegal routeTypical treatment of third-party data
The person the case is aboutUK GDPR right of access / Privacy ActFile released; other people's data removed unless consent or reasonable to disclose
Court or tribunalDisclosure rules, administrative recordFull record, with sensitive third-party data flagged or filed under the privacy rules
Member of the publicFOIA or state public records lawPartial release; stricter than for a party
Publication, training, statisticsPolicy decisionFull anonymisation of the case file

Case files mix ordinary personal data (names, addresses, phone numbers, signatures, registration plates) with more delicate information: health details in care or benefits cases, children's data in education and social care files, and allegations in enforcement cases.

The consistency problem

  • A name redacted in the report but visible in the cover letter or delivery receipt.
  • The same neighbour blacked out in one document, called “Neighbour A” in another and “Witness 2” in a third, which makes the narrative impossible to follow.
  • Scanned photos or plans no one checked because they were “just images”.
  • A second release months later using different choices from the first.
  • The requester's name in the file name or in document metadata.

When the recipient needs to follow who said what, pseudonymisation usually works better than black boxes: each person gets a stable label (“Person 1”, “Person 2”). For that to work, the label must be identical across the whole case file.

A workflow for case teams

Before releasing or filing a case file

  • Identify the recipient and the legal route: party, court, public request or publication.
  • List the people in the file and decide for each whether to keep, remove or pseudonymise.
  • Apply the same choices and the same label table to every document.
  • Check scans, photos and appendices, not just native documents.
  • Rename files neutrally and strip metadata.
  • Keep the released version and record what was removed and why.

How Anonimatum helps with case files

Since version 1.9.0, Anonimatum has a Case files screen: group the documents of a case, apply the same template to all of them through the background queue and track the status of each one. Each case file can have a shared map, so the same data receives the same substitute in every document; each map has its own password, which is not stored.

You can download the case file as a ZIP with the finished documents and an index in CSV and PDF without names or personal data. Every run saves a version in the version history (up to 10 per document, encrypted and without the file name), and the resulting PDF can be published to your case management system (REST or CMIS) with a neutral name and metadata free of personal data. Detection combines Anonimatum's own AI on EU servers, patterns for IDs and bank details and OCR for scans, and a whitelist keeps signing officials visible.

Frequently asked questions

Does the person have a right to know who complained about them?

Not automatically. Under the UK GDPR the complainant's identity is third-party data, disclosed only with consent or where reasonable. Often the substance of the complaint is shared without the identity.

Should the record filed with a court be redacted?

Courts generally receive the full record, but filings must follow the applicable privacy rules, such as FRCP 5.2 in US federal courts, and sensitive third-party data can be flagged for the court to decide on.

Pseudonymise or redact?

If the recipient must follow the narrative, stable pseudonyms are clearer. If the document will be published, irreversible redaction is the safe option.

How do I keep two releases of the same file consistent?

Store the choices and the label table for the case and reuse them. With a shared map, a person always receives the same substitute, even if a document is processed months later.

Keep every case file consistent

See the plans and start organising and redacting your case files today, with shared maps and version history.

Sources and legislation

  1. Data Protection Act 2018, Schedule 2, Part 3 (legislation.gov.uk)
  2. ICO: When can an exemption apply to information about other people in a SAR?
  3. US Department of Justice: Privacy Act of 1974
  4. US Courts: Federal Rules of Civil Procedure