What is de-identification?
Also called: de-identified data, anonymization.
Short answer
Removing or replacing names, account numbers and other details so a client can't reasonably be identified from the information.
Definition
De-identification means stripping out or swapping the details that identify a person (names, account numbers, addresses, exact dates of birth) so what's left can't reasonably be tied back to them. Our AI policy template defines de-identified information as information from which those details have been removed or replaced so the client can't reasonably be identified from it alone.
In practice, advisors do it by using placeholders like "Client A" and rounding figures.
Why it matters for advisors
De-identifying a question is how many firms let advisors use general AI assistants for planning help without putting client data in the tool. It's simple, fast and lowers risk.
It's also easy to get wrong, because combinations of ordinary details can still point to one person.
It also matters for what you test with. When trialing a new AI tool before due diligence is done, the safe practice is to use made-up or properly de-identified examples, never a real client's file.
Example
Instead of "Jane Smith, 62, $2.4M IRA at Schwab, retiring from Acme in May," the advisor asks about "a client in her early 60s with a seven-figure IRA, retiring next year."
Watch out for
If your firm is small and the details are unusual, even de-identified facts can be recognizable. When in doubt, use an approved tool.
Related terms
- Personally identifiable informationInformation that identifies a specific person, alone or combined with other data: name, address, Social Security number, account number.
- Nonpublic personal informationUnder Regulation S-P, personally identifiable financial information about a client that isn't publicly available, such as balances and tax data.
- PromptThe instruction or question you give an AI tool, plus any text or files you include with it.
- Shadow AIAI tools staff use for work without the firm's approval, such as personal chat accounts or unvetted browser extensions.
Learn more
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