APP 2: Anonymity and Pseudonymity

APP 2.1 states that individuals must have the option of not identifying themselves, or of using a pseudonym, when dealing with an APP entity in relation to a particular matter. The obligation is not absolute: APP 2.2 removes it where identification is required or authorised by law, or where it is impracticable for you to deal with an unidentified or pseudonymous individual.

In practice, this principle is most relevant to the early stages of a customer relationship — general enquiries, price checks, browsing a service before committing — rather than to a completed transaction, where identification is usually necessary to deliver goods, process payment, or meet another legal obligation.

Any business that has enquiry channels — a contact form, a phone line, a live chat widget, a physical counter — needs to consider whether it is genuinely necessary to collect a name and contact details at that stage, or whether the enquiry could reasonably be handled without identifying the person first.

• Mandatory name/email fields on general enquiry forms where the enquiry itself does not require identification (e.g. "what are your opening hours?").
• Requiring account creation to view basic information that could reasonably be public.
• No pseudonym option in support channels for non-transactional questions.

1. Review your enquiry and contact channels — identify which fields are genuinely required versus merely convenient to collect.
2. Make optional fields optional in practice, not just in principle.
3. Where full identification is necessary (payment, delivery, regulated services), be transparent about why via your APP 5 collection notice.
4. Train front-line staff to accept general enquiries without insisting on a name where it is not needed.