Tomlin Order and settlement agreement: pseudonymise before circulation – UK GDPR-compliant anonymisation
A Tomlin Order is a consent order that stays proceedings on agreed terms contained in a confidential schedule, enabling parties to settle without those terms entering the public court record; anonym.legal pseudonymises personal data in draft orders and schedules — according to HMCTS Civil Justice Statistics, hundreds of thousands of claims settle each year, many via Tomlin Orders in disputes above £25,000.
When this applies
Applies when a solicitor is drafting a Tomlin Order schedule or settlement agreement that names individuals — guarantors, beneficiaries, employees, or other third parties. The multi-track threshold is above £25,000; Tomlin Orders in commercial disputes can reference 5 or more named third parties in the confidential schedule.
How anonym.legal handles it
- Upload the draft Tomlin Order (or consent order) and attached schedule in DOCX or PDF.
- Configure the party-names allow-list to retain named parties' names in clear.
- anonym.legal pseudonymises third-party names, account numbers, property addresses, and other personal identifiers in the schedule.
- Settlement terms, financial obligations, and procedural provisions are preserved in full.
- A reversible mapping is stored with EU data residency.
- Re-identify from the mapping key before the order is engrossed and submitted to the court.
What you provide
- Draft Tomlin Order or consent order body (DOCX or PDF)
- Draft settlement schedule
- Party-names allow-list
Limitations & cautions
- The final Tomlin Order submitted to the court must contain accurate party names and terms — always re-identify completely before submission.
- anonym.legal does not review the enforceability or legal effect of the settlement terms.
- Settlement schedules containing third-party personal data must comply with UK GDPR; misuse can attract fines of up to £17.5 million or 4% of global turnover under DPA 2018 s.157.
FAQ
What distinguishes a Tomlin Order from a standard consent order in civil proceedings?
A Tomlin Order stays the proceedings with confidential terms in a schedule, which does not become part of the public court record. A consent order disposes of the proceedings on terms that are on the record. According to HMCTS guidance, both forms are used across hundreds of thousands of settled claims annually.
Can I pseudonymise the settlement schedule separately from the order body?
Yes — upload the schedule and order body together in one session for consistent pseudonymisation, or upload them separately if that suits your workflow.
Are property addresses and bank account details pseudonymised in settlement documents?
Yes — property addresses, bank account numbers, and sort codes are recognised as personal-data identifiers and pseudonymised by default. Research shows that settlement schedules in commercial cases regularly contain financial identifiers for 3 or more individuals.
Related tasks
- Without prejudice mediation correspondence: pseudonymise before internal review
- Costs Schedule (N260): pseudonymise fee-earner and client details before submission
- Particulars of Claim: pseudonymise third-party identifiers before drafting review
- Defence and Counterclaim: pseudonymise third-party data in draft pleadings