Blog · Data quality and reconciliation
A practical method for pseudonymising a sales export before it leaves the firm: which columns identify a person or a client, how to build a stable ID mapping in a spreadsheet the firm keeps, what stays personal data under UK GDPR anyway, and how to check the file still reconciles afterwards.
Most firms would let an analytics tool see their numbers and would never let it see their client names. The two can be separated in ten minutes with a spreadsheet, and nothing about the analytics changes. This guide sets out how, what it does and does not achieve legally, and how to check nothing broke.
| Column type | Replace? | With |
|---|---|---|
| Client or account name | Yes | A stable client ID |
| Contact name, email, phone | Yes | Drop, or a contact ID |
| Salesperson name | Yes, preferably | A salesperson ID |
| Free-text notes | Yes | Drop |
| Region, team, product, date, value | No | Keep as they are |
The measures need the identifier to be stable across rows and across periods. They never need the name.
Reuse the same mapping every period. A client whose identifier changes between quarters becomes two clients in the roll-up.
Before the pseudonymised file goes anywhere, check three things against the original:
If the third check fails, two clients were given the same identifier, or one client had two spellings of its name and got two identifiers. Both will show up later as a variance in the roll-up, so it is cheaper to catch them here.
Under UK GDPR and the EU regulation, data that can be re-identified with information held separately is pseudonymised, and pseudonymised data remains personal data. The firm still needs a lawful basis and a data processing agreement with any vendor. What changes is the risk: a vendor holding identifiers and figures cannot identify anyone without the firm's mapping, and the security measures expected of it, and the consequences of a breach, are correspondingly lighter. Many firms' compliance teams will approve a pseudonymised upload without the full vendor review a named dataset would need.
Anonymisation, where re-identification is impossible for anyone, is a higher bar and is rarely achievable for sales data, because the firm always keeps the mapping. Say pseudonymised, not anonymised.
Before:
| Client | Salesperson | Product | Revenue |
|---|---|---|---|
| Northgate Holdings | Priya Raman | FX forwards | 412,000 |
| Northgate Holdings | Priya Raman | FX options | 96,000 |
| Kestrel Capital | Sam Kaur | FX forwards | 220,000 |
After:
| client_id | sp_id | Product | Revenue |
|---|---|---|---|
| C-2291 | SP-03 | FX forwards | 412,000 |
| C-2291 | SP-03 | FX options | 96,000 |
| C-0876 | SP-04 | FX forwards | 220,000 |
Three rows, 728,000 in total, two distinct clients, before and after. The mapping, two rows, stays in the firm.
Spelling variants. "Northgate Holdings" and "Northgate Holdings Ltd" become two identifiers. Normalise names before mapping, or map both spellings to one identifier.
Identifiers that change. A mapping rebuilt from scratch each quarter with a new running number. Keep the mapping and append to it.
Names hiding in other columns. A notes column, an invoice reference containing the client name, an email address as the contact. Check every text column.
Calling it anonymised. It is not, and a compliance team will notice.
Covirage works entirely on identifiers, and on Enterprise runs in a separate pseudonymised tenant. The upload page reads the file in the browser and checks it before anything is stored, and the glossary entry on pseudonymised data has the short version of the legal position.
Under UK and EU GDPR, yes, as long as anyone can re-identify it, which the firm can with its mapping. Pseudonymisation is a recognised safeguard that reduces risk and the obligations on a processor, not an exemption. A data processing agreement is still needed.
Client or account names, contact names, email addresses, phone numbers, and free-text fields that might contain any of those. Product names, regions, salesperson identifiers and figures can usually stay. Salesperson names are personal data too, and a salesperson identifier is the safer choice.
Fully. Every measure joins on the identifier and rolls up by it. The only thing a name adds is readability on screen, and the firm can keep that by joining the mapping back locally.