QA2025-51- Anonymisation in B90.00

Question

For B90.00 “Counterparties”, column c0040 Counterparty name and c0050 Counterparty identifier (preferably LEI) , in the case of natural persons, the name and identifier of the counterparty should be anonymized by the reporting entity. Which of the following anonymization methods should be used? If all don't apply, please explain how the anonymized data should be done. * Randomization of values to prevent identification using String data types (with which minimum length and other requirements?) * Assign the position empty * Assign a fixed value such as “Anonymised”

Response

The MBDT Guidance does not prescribe a specific method for anonymizing certain data fields, such as Counterparty name (c0040) and Counterparty identifier (preferably LEI) (c0050) in tab B90.00. However, we recommend to replace these data points with internal unique identifiers that allow the institution to map such IDs to the actual counterparties, while ensuring that the Resolution Authority cannot identify them. For example, this means that the bank can assign a unique identifier, consistent across both fields (c0040 and c0050), which is meaningful only to the institution. This approach will enable the institution to maintain the necessary internal references while protecting the confidentiality of the natural person's identity.

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