Witness Statement under CPR Part 32: pseudonymise third-party identifiers – UK GDPR-compliant anonymisation per CPR Part 32
A witness statement is the formal written evidence served under CPR Part 32 in which a witness sets out their account of relevant facts; anonym.legal replaces non-party identifiers with consistent pseudonyms across the statement and exhibits — research shows that over 1.4 million civil claims proceeded in 2023, generating substantial volumes of third-party personal data (HMCTS Civil Justice Statistics).
When this applies
Applies when a solicitor is preparing or reviewing a witness statement that names or describes third parties not party to the proceedings. According to CPR Part 32, witness statements must be verified by a statement of truth; the small claims track threshold is £10,000, and statements appear across all tracks.
How anonym.legal handles it
- Upload the draft witness statement and any exhibits in DOCX or PDF format.
- anonym.legal identifies third-party names, addresses, telephone numbers, and other personal identifiers throughout the statement.
- Each non-party is pseudonymised consistently so all references to the same individual are replaced with the same pseudonym.
- The deponent's own name and the names of parties are retained in clear (configured via the party-names allow-list).
- The factual narrative, dates, and evidential content remain unaltered.
- An encrypted reversible mapping is stored; the solicitor can restore clear names when finalising the statement for service.
- The final served version is produced by re-identifying from the mapping key before signing and filing.
What you provide
- Draft witness statement (DOCX or PDF)
- Exhibits annexed to the statement
- Party-names allow-list (claimant, defendant, deponent)
Limitations & cautions
- The statement of truth and the deponent's identity must appear in clear in the filed version — confirm re-identification before service.
- anonym.legal does not verify that the statement complies with the CPR Part 32 formal requirements (e.g. heading, statement of truth wording).
- Unauthorised disclosure of third-party personal data extracted from witness statements can attract UK GDPR enforcement; fines can reach £17.5 million or 4% of global annual turnover under DPA 2018 s.157.
FAQ
Can the same pseudonym session cover multiple witness statements for one matter?
Yes, upload all statements together in one session so the engine assigns consistent pseudonyms across the full set — 'Witness A' in statement one will be the same individual as 'Witness A' in statement two. Data shows that multi-witness matters frequently involve 5 or more statements.
Does pseudonymisation extend to photographs or plans annexed as exhibits?
Image-based exhibits are not currently processed for embedded text. Redact any personal data in image exhibits manually before upload.
Is the pseudonymised draft suitable for sharing with counsel for legal opinion?
Yes — sharing pseudonymised drafts with counsel limits data exposure at the advice stage. According to the ICO Code of Practice on Anonymisation (2021), pseudonymisation is a recognised risk-reduction measure for internal sharing of personal data.
Related tasks
- Expert Report under CPR Part 35: redact non-party personal data
- Specific Disclosure Application under CPR Part 31: prepare redacted exhibit
- Redacted exhibits under CPR Part 31: pseudonymise non-party data in disclosed exhibits
- Third-party witness materials: pseudonymise before sharing with instructed experts