Versatile AI Risk Assessment
Documents and casework

Automated anonymisation and redaction

Also known as: Automated anonymisation, PII redaction

The system finds names, addresses and other personal information in documents and suggests redactions for a person to approve.

Explore the interactive model

Export handout

A concise PDF covering how the system works, its data flows and points to investigate, ready to share.

The explanations and measures describe the typical system design. Extensive personal changes add an appendix.

Understand the use case

What defines this use case?

Courts in Baden-Württemberg and Hesse use this approach to anonymise judgments before publication. Amsterdam uses it to redact documents released in response to access requests.

This page describes a typical system design. Actual data flows and permissions depend on your implementation.

System design
Analysis and processing
Ability to act
Action permissions depend on integration
Fields of use
judiciary, public administration
Also known as
redaction software, pseudonymisation, PII detection

How it works, step by step

System design and data flows

  1. Input data

    A judgment, file or other document is to be published or released.

    Pleadings, applications and correspondence also come from parties and people outside the organisation. For scanned documents, the system analyses images and text together to place redactions correctly.

  2. Processing

    A detection model searches for names, addresses and other information that identifies a person.

    A detection model marks passages or image regions that can be linked to individuals. An editing component replaces or removes the selected areas. Detection, suggestions and effective technical removal are separate steps; a visible black rectangle alone does not tell you which data remain in the file.

  3. Results

    The system suggests redactions or placeholders for a staff member to review and approve.

    The result describes the defined model task. A match, category or forecast acquires its professional significance only in conjunction with the underlying data and intended use.

  4. Use and impact

    The edited document is published or released to the requesters.

    Integration determines whether the result is simply displayed, adopted after approval or written directly into a business application. These variants differ in their data flows and permissions.

Explore the system design: Select a component to see its task, incoming and outgoing data, and role in the use case. The guided walkthrough explains each phase. Then use Yes, Uncertain and No to represent your specific system variant.

How the system is built

5 review first17 clarify8 baseline threats

InputProcessingResultImpact Externalaccess 05 Input 31 Third-partycontent 00 AI model 05 Providerservice 01 Documentcollection 00 Memory 00 Training andfeedback 12 OtherAI agents 00 Tools andinterfaces 00 Result 01 Business appor equipment 01 person 10 Affectedperson 00 AI serviceswithout approval 01 Externalaccess 05 Input 31 Third-partycontent 00 AI model 05 Providerservice 01 Documentcollection 00 Memory 00 Training andfeedback 12 OtherAI agents 00 Tools andinterfaces 00 Result 01 Business appor equipment 01 person 10 Affectedperson 00 AI serviceswithout approval 01
  • Present
  • Depends on your system
  • Absent
  • Review first
  • To clarify

In this system design: 5 to review first, 17 to clarify, 8 baseline threats.

Architecture as a list

How it differs from similar use cases

Data and information

Input data and information sources

Pleadings, applications and correspondence also come from parties and people outside the organisation. The system specifically searches for names, addresses, dates of birth and other personal information.

Processing and operating environment

The model processes the inputs. Whether it runs internally or with a service provider must be established for the specific implementation.

Storage and further use

Some deployers further train detection using their own judgments or files. Corrections made during approval can feed back as new training examples.

Results and data sharing

Depending on the workflow, redactions take effect immediately or only after approval; JANO and Amsterdam both require human approval. With a cloud service, documents leave the organisation's environment before they are redacted.

Using a provider does not automatically determine where processing takes place. Storage location, subcontractors, deletion periods and use for training must be checked for the specific deployment.

Assess risks and determine measures

From understanding the system to analysing risks

  1. Define the system boundary

    Record data, participants, interfaces and permissions. Resolve uncertain characteristics in the model.

  2. Investigate threats

    Relate review candidates to actual data flows: what could happen, and who would be affected?

  3. Assess risk

    Assess impacts and likelihood in the deployment context. The number of review candidates is not a risk score.

  4. Provide evidence of measures

    Select appropriate controls, assign responsibilities and define effectiveness checks. Document residual risks and approvals.

Key threats in the application context

  • 3 particularly important
  • 2 typical
  • 17 depending on the system
  • 8 additional threats for every AI system

A total of 30 threats from the threat catalogue may be relevant to this use case.

Priority review points

  1. Sensitive Information Disclosure

    The system misses an unusually spelt name or information in a footnote. The document is published and the person can be identified.

  2. Privacy Attacks

    Names are redacted, but occupation, place of residence and the time of the offence remain. Comparing the published judgment with other sources can still identify the person.

  3. Overreliance

    Most suggestions are correct, so approval becomes routine. Missed passages are then discovered only after publication.

2 further review candidates in the typical design

Other relevant threats

  1. Targeted Poisoning / Label Poisoning

    Falsified training labels can deliberately shift model outputs.

    Listed because of this characteristic

    • Learns from examples with correct answers
  2. Exfiltration from ML Application

    Protected data can leak through tools, network connections, storage or insiders.

    Listed because of this characteristic

    • Processes confidential data

Up to 17 further threats may apply, depending on your system design. Nine threats need to be reviewed for every AI system. One of these is particularly important here and is therefore listed above.

System features and open questions

Each Yes adds further threats to your checklist, up to 17 in total. If you cannot yet answer a question, include its threats in your review.

How many threats a Yes adds
  • Added by this Yes
  • Also requires a Yes to another question

How your system is built

  1. Performs natural language tasks5 threats
  2. Generates its own text2 threats, plus 1 only in combination with other characteristics
  3. Learns from your own data2 threats, plus 1 only in combination with other characteristics
  4. Processes text, images and speech together2 threats
  5. Changes data or triggers processes1 threat
  6. Uses another provider's model1 threat
  7. Uses operational feedback1 threat

How you operate the system

  1. Accepts queries directly through an interface4 threats, plus 1 only in combination with other characteristics
  2. Accessible over a network2 threats, plus 1 only in combination with other characteristics
  3. Incurs costs with each query1 threat
  4. Shares computing resources with other customers or applications1 threat
  5. Used alongside unapproved AI services1 threat

How your system is built

Can the system change things itself, such as storing data, sending messages, initiating transactions or granting permissions?

Depending on the workflow, redactions take effect immediately or only after approval; JANO and Amsterdam both require human approval.

If yes, add

Does the model or its base model come from another provider, even if you host it?

If yes, add

Does operational feedback or output later feed into analysis or training?

Corrections made during approval can feed back as new training examples.

If yes, add

Does the system process several input types together, such as text with images or speech?

For scanned documents, the system analyses images and text together to place redactions correctly.

If yes, add

How you operate the system

These questions arise for almost every AI system.

Controls and implementation

Measures for the priority review areas are expanded. Each linked measure explains how to implement it.

Controls for the remaining threats are available on their pages in the threat catalogue.

AI Act provisions

Applies to every AI system

Art. 4: AI literacy

Applies if staff or appointed representatives operate or use AI systems.

Applies since 2 February 2025.

Obligations and details for Art. 4: AI literacy
Who bears the obligations
Provider, Deployer, Product manufacturer, Provider of a general-purpose AI model

Detailed obligations

Generally does not apply

Annex III no. 8 point a: Administration of justice

The system prepares judgments for publication. It does not help courts establish facts or interpret legal provisions.

Obligations and details for Annex III no. 8 point a: Administration of justice
The general condition is
Applies if the system helps courts or dispute resolution bodies establish facts and interpret law.
Exception
Purely ancillary tasks such as anonymising judgments or staff communication are excluded under recital 61.
Who bears the obligations
Provider, Deployer, Product manufacturer

Detailed obligations

Classify your system with the quick checker All obligations in the obligations compass

Cross-cutting threats

Review these threats for every AI system, whatever its purpose.

Why these threats always belong on the checklist

Atypical system features

View 15 further questions

If any of these features does apply to your system, add the listed threats.

Sources

Related use cases

Also in the field of Documents and casework

Often used together with

Updated: 30 September 2026. Review checklist rules version 0.3.2, threat catalogue version 2026.10.24.2. How these pages are structured