Data privacy guide
Direct answer
Yes. An initial BHPH portfolio grade can usually begin with a de-identified account tape that uses internal account IDs and includes contract terms, balances, payment performance, delinquency, vehicle information, and account status. Customer identity and source documents are generally handled later through secure diligence if the transaction advances.
Direct identifiers to leave out of a first-look tape
- Customer and co-buyer names
- Social Security and taxpayer-identification numbers
- Driver-license numbers
- Street addresses, personal email addresses, and phone numbers
- Bank-account, routing, debit-card, and other payment-instrument information
- Copies of identity documents
Replace names with a stable internal account ID. That ID lets the dealer and buyer discuss individual records and later match an accepted pool to the source system.
Data that still makes the tape useful
De-identification should not remove the fields that explain the receivable. Keep origination date, original amount, payment amount and frequency, balance, next due date, last payment date, total collected, payment count, delinquency, account status, vehicle details, title status, and any material exception flags.
A VIN can be relevant to collateral analysis. If you prefer to limit it during first look, ask whether a shortened VIN plus year, make, and model is sufficient until diligence.
A practical two-stage review
- Initial grade. Send a de-identified account tape through the secure upload. The buyer reviews composition, performance, collateral, and data quality.
- Indication and pool discussion. Confirm which accounts fit, discuss assumptions, and resolve missing fields.
- Diligence. After the parties decide to move forward, provide customer records, contracts, titles, and supporting documents through the approved secure process.
- Closing. Final schedules, balances, documentation, and transfer requirements are reconciled before funding.
When customer identity may be needed
Identity and source documents are normally needed before a buyer can verify ownership, documentation, liens, account eligibility, and transfer requirements. The timing and required documents depend on the transaction, applicable law, and the buyer's diligence process.
Share sensitive files securely
- Use the site's secure portfolio upload instead of ordinary email for files containing customer data.
- Limit the file to information requested for the current stage.
- Confirm the recipient before granting access.
- Keep a record of the version and date shared.
- Follow your dealership's privacy, retention, and incident-response procedures.
Frequently asked questions
Can I remove the customer name but keep the account number?
Yes. A stable internal account ID is useful for analysis and later reconciliation as long as it does not itself reveal unnecessary customer information.
Should I email a file containing Social Security numbers?
Use an approved secure transfer method for sensitive diligence files. A first-look tape normally does not need Social Security numbers.
Will removing PII guarantee an offer?
No. De-identification protects customer information during the initial stage, but valuation still depends on account performance, collateral, documentation, and the buyer's criteria.
Sources and related resources
Software menus and reports can change. This guide was last checked on September 26, 2026.