Redaction Policy
London Borough of Barnet
DATA PROTECTION
11
Data Protection – Redaction Policy
Document Control
Document
Description
Redaction Policy
This document details the process which should be applied when
redacting information prior to disclosure / publication of information.
This policy is written in conjunction with our obligations under the
Data Protection Act 1998 and Freedom of Information Act 2000.
Version
V1
Date Created
April 2012
Status
Approved
Authorisation
Name
Date
Prepared By:
XXXXXX
April 2012
Checked By
Standard and Information Rights Team (SIRT)
April 2012
Approved by
Information Governance Council (IGC)
May 2012
Version Control
Version
Date
number
V 1.1
April 2012
V 1.2
May 2012
V1.2
Jan 2014
Author
Reason for New Version
XXXXXX
Creation of Policy and Toolkit
Comments and approval
Review
IGC
XXXXXX
Date last reviewed:
Date of next review:
April 2012
April 2013
Data Protection – Redaction Policy
Contents
1
2
3
4
Introduction ...................................................................................................... 1
Scope .............................................................................................................. 1
Key legislation ................................................................................................. 1
What is redaction ............................................................................................. 2
4.1
Key principles for redaction................................................................... 2
5
Identifying material for redaction...................................................................... 3
6
Withholding without redaction .......................................................................... 3
7
Redaction and scanning .................................................................................. 4
8
Delegated Powers Reports (DPR), ‘Exempt’ Committee reports/ etc: ............. 4
9
Commonly redacted information ...................................................................... 4
9.1
Names and contact details.................................................................... 5
9.2
Pronouns .............................................................................................. 6
9.3
Bank details .......................................................................................... 6
9.4
Signatures............................................................................................. 6
9.5
Declaration of interests ......................................................................... 6
9.6
Gifts and Hospitality .............................................................................. 6
9.7
Planning ................................................ Error! Bookmark not defined.
9.8
Sole trader information.......................................................................... 6
10
Contact information ......................................................................................... 6
REDACTION TOOLKIT .............................................................................................. 8
1
Introduction
Barnet Council routinely publishes information and is continually striving to be
a more transparent organisation. Information is published in various ways,
including via the website, leaflets, newsletters, brochures and similar
documents that are published specifically to provide information to members
of the public about services provided by the organisation. There are other
instances where information is published where redaction is more likely to
apply, because the documents being considered for publication contain some
confidential information that must be made unreadable ahead of publication:
This policy and accompanying toolkit has been produced to provide guidance
on the editing of exempt material from information held by the London
Borough of Barnet. Its purpose is to assist in the implementation of the
Freedom of Information Act 2000 (FOIA) and the Environmental Information
Regulations 2004 (EIRs), whilst complying with our obligations under the Data
Protection Act 1998 to protect personal information.
Under the FOIA and EIRs, the council is required to supply information to
anyone that requests it unless an exemption applies. Even then there is a
further requirement, in most cases, to consider whether the public interest lies
in favour providing the information or maintaining the exemption.
This guidance is based on the Redaction Toolkit for the Editing of Exempt
Information from Paper and Electronic Documents Prior to Release (version
2.1, 2011) published under Crown Copyright by the National Archives.
2
Scope
This guidance is aimed at FOI/SAR Link Officers and any other officers who
handle requests for information under the FOIA, the EIRs and the DPA, or
undertake any process of redaction.
3
Key legislation
The main legislation which require that redaction is carried out before
information is disclosed, are listed below. This list is not exhaustive and other
legislation may require the release of information redacted where applicable.

Data Protection Act 1998

Freedom of Information Act 2000

Environmental Information Regulations 2004

Common Law Duty of Confidentiality
The Data Protection Act 1998 prohibits the processing, which may include
publishing, of personal data unless certain conditions are met (for example, if
an individual has given consent for data about them to be processed).
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Personal information means information which relates to a living individual
who can be identified:
(a) from that information, or
(b) from that information and other information in the possession of the Data
Controller. This will include any expression of opinion about the individual
and any indication of the intentions of the Data Controller, or any other
person, in respect of the individual.
Even if certain conditions for processing are met, Section 10 of the Data
Protection Act 1998 gives individuals the right to stop the processing of their
data if it causes damage or distress which is unwarranted.
4
What is redaction
Redaction is a process which is undertaken to render information unreadable.
This is done by blocking out individual words, sentences or paragraphs or by
removing whole pages or sections prior to the release of the document.
4.1
Key principles for redaction

Redaction is carried out in order to remove exempt information from a
document. It should be used when one or two individual words, a
sentence or paragraph, a name, address or signature needs to be
removed.
However, if so much information is deemed to be exempt and the
document becomes nonsensical, the entire document should be withheld.
When responding under FOI you must ensure you state what exemption
the information has been redacted / withheld under, this should be done
for every exemption, either in the covering response letter or if more than
one exemption has been applied, this should be clearly marked on the
document itself next to the redacted area.

Redaction must never be undertaken on an original document. A copy
must be taken first to ensure all the information contained in the original
document remains intact.
This ensures that while the redacted information is permanently removed
from the copy of the record, which can then be made accessible, the
original text remains in the original record. Redaction can be challenged
and for this reason the unredacted document must always be kept related
to the redacted version. Redaction should never result in the complete
removal or amendment of text or information from an original record.

When undertaking redaction, reviewers should consider whether any other
factors are important for the understanding of the material. For example, if
colour within a document makes the meaning clear, a redacted colour
copy should be released.
2
5

Redaction should be performed by the service who holds the information
and by staff that are knowledgeable about the records and can determine
what material is exempt.

Redactions shouldn’t just be blank space, it should be clear that redactions
have been made to a document. The amount of information redacted
should also be clear.

Applicants may request that information be presented to them in electronic
form. For paper documents, this will usually mean scanning the redacted
version of the document.

Under FOIA the reason for the redaction must always accompany the
redacted document, for example, “redacted as it is considered to be
personal data under Section 40 of the Freedom of Information Act 2000”.
Identifying material for redaction
All staff should be aware of the requirements of the Data Protection Act and
ensure personal data is not released in breach of the Act. Further guidance
can be found in the Data Protection Policy.
In order to comply fully with a request for information, it is essential that only
exempt material be redacted. A whole sentence or paragraph should not be
removed if only one or two words are non-disclosable, unless release would
place the missing words in context and make their content or meaning clear.
Reviewers should also consider that earlier statements in a document might
suggest the content of removed material. For example, if a paragraph refers
to reports from overt sources, and the following paragraph refers to reports
from covert sources, as well as removing the words ‘covert sources’, ‘overt
sources’ would also need to be removed or the meaning of the missing words
from the second paragraph could be inferred.
Records should also be checked for other copies of the same documents so
that redaction is carried out consistently, and indexes should be checked to
ensure that they do not contain details of the redacted material.
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Withholding without redaction
Redaction only applies where certain elements of a page of a document can
be released and certain elements must be withheld. If it is decided that a
whole document or a page or pages of a document are not to be disclosed,
then the information contained within it does not need to be redacted.
Instead, the information can be withheld in total. Where such information is
withheld this must be referenced in any response or stated when published.
For example: “This report is 30 pages long, pages 23 to 25 have been
withheld as they are exempt under section 43 of the Freedom of Information
Act 2000”
3
7
Redaction and scanning
Once redactions have been made on copies of documents, you must ensure
that the redacted text is completely illegible on the final copies to be released.
When redacting by hand with a black marker pen the best approach to take is
to scan the documents on an MFD on the “Black and White” and “Text”
settings. This should ensure that the text does not show through. However,
you should always check that the text is unreadable before releasing
documents.
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Delegated Powers Reports (DPR), ‘Exempt’ Committee reports/ etc:
An exempt DPR or a report that was exempt when it went to committee is not
automatically exempt under FOIA.
Although Schedule 12A of the Local Government Act states that certain
information is exempt information this does not operate as a statutory bar and
s.44 of the Freedom of Information Act, which covers information prohibited
from disclosure under other legislation is not applicable.
This correct interpretation is:

Schedule 12A lists the information that is exempt from the requirements of
Part VA, and not information that is exempt from disclosure under any
other regime.

Consideration of disclosure under the FOIA requires the application of the
FOIA categories of exempt information to the information and not the
Schedule 12A description of exempt information.

Nothing in Part VA or Schedule 12A actually prohibits the disclosure of
information. At no point is it provided that such information should not be
disclosed, merely that it is not subject to the Part VA requirement to
disclose. Therefore, s.44 of FOIA cannot apply.
However, this does not mean that all information exempted under Schedule
12A must be released as a result of requests for information. Whilst it may be
the case that all of the report can be released under the FOIA, it may well be
that one or more of the exemptions and exceptions contained within the FOIA
and EIR would apply. It may also be the case that some DPRs/reports
exempted under Schedule 12A lose their sensitivity over time.
When considering what to release in response to a request for exempt
DPRs/reports, the section below should be consulted.
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Commonly redacted information
The following are details which are commonly redacted. In all cases where
redactions are undertaken, the reasons must be stated and the relevant
exemptions/exceptions applied.
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9.1
Names and contact details
9.1.1 Freedom of Information
Names and contact details of individuals should not be disclosed as a matter
of course.
It is council policy, in line with guidance issued by the Information
Commissioner’s Office (ICO), not to routinely release the names and contact
details of officers below the level of Head of Service or senior officers whose
details are listed on the corporate structure chart .
There may be circumstances where it is appropriate to release the details of
more junior officers and similarly where the names of senior officers should be
redacted. For example, if officer names are in the public domain through
attendance at a public meeting, then there would be no need to redact them
from the published minutes. If you are unclear as to the approach you should
take, please contact the Information Management Team.
9.1.2 Subject Access Requests
When dealing with the redaction of names in relation to Subject Access
requests, disclosure considerations are slightly different. We should look to
be as transparent as possible whilst still taking into account any conflicts of
interest or confidentiality concerns.
The rights of the individuals named on documentation should be weighed
against the right of access of the individuals who is seeking the information
and a decision made based on this.
Considerations are: Information generally known by the individual making the request - If the
name of an individual or council officer has previously been provided to the
individual i.e. a member of staff (acting in the course of their duties), who is
well known to the individual making the request through their previous
dealings, would be more likely to be disclosed than information relating to an
otherwise anonymous private individual.
Circumstances relating to the individual making the request – If the names of
the officers involved have been the ones that have made key decisions and
choices in regards to the individual, it may be deemed appropriate to release
their names.
Consent – where there is uncertainty as to whether to disclose an officer
name or nor it is considered good practice to consult with affected officers to
seek consent rather than applying a blanket redaction approach.
Further guidance and advice should be sought from the Information
Management Team if in doubt.
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9.2
Pronouns
When redacting names you must follow the redaction through, by redacting
any pronouns which relate to the redacted names. e.g. her/his, he/she.
9.3
Bank details
The bank account details of both individuals and businesses must be
redacted from all documents that are to be released into the public domain.
9.4
Signatures
In most cases, signatures constitute personal data as they can identify the
person signing.
9.5
Declaration of interests
The ‘declaration of interest’ form completed by council officers is subject to
FOIA. However in line with the council’s policy on non-disclosure of names
and job titles of officers below the level of Head of Service, forms completed
by junior officers are considered exempt. Forms completed by Heads of
Service while subject to FOI may need to be redacted as some information
contained may constitute personal data. This should be done on a case by
case basis.
9.6
Gifts and Hospitality
The gifts and hospitality register is subject to disclosure under FOIA.
However, names of junior officers should be redacted in line with the council’s
policy.
9.7
Sole trader information
The Code of Recommended Practice for Local Authorities on Data
Transparency states that ‘any sole trader or body acting in a business
capacity in receipt of payments of at least £500 of public money should expect
such payment to be transparent.’ The code further advises these individuals
should be informed that their information will be published and they can object
if the disclosure would cause them unwarranted damage or distress. In line
with this, the council releases the names of sole traders in the over £500
spend list. Finance informs sole traders and keeps a record of sole traders
where it has been agreed that those name will not be disclosed.
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Contact information
For further advice on the provisions of the Freedom of Information Act 2000,
the Environmental Information Regulations 2004 and the Data Protection Act
1998, please contact the Information Management Team at:
Email:
Address:
[email protected]
Information Management Team
6
London Borough of Barnet
Building 2
North London Business Park
Oakleigh Road South
London
N11 1NP
7
REDACTION TOOLKIT
Appendix 1
Redaction of documents in hard copy
Methods of redaction
There is a range of redaction methods, and any may be used effectively according to
what best suits the Service concerned. This may depend on issues such as the
structure and content of the document, the degree of confidentiality, and the cost and
time available. However, whichever method is employed, the end result must ensure
that the redacted material cannot be seen or guessed due to incomplete redaction.
This means checking to make certain that words cannot be made out when the
document is held up to light or that the ends, top or bottom of text are not visible.
Cover-up tape. One form of redaction is to use a high quality cover-up tape that can
be placed on the original documents over the areas to be redacted, taking care that
no parts of words are showing. This can then be photocopied to produce a version
fit for disclosure. The tape is white, and acts in much the same way as if using
correction fluid, but can be reused several times. It is available in 1/6” for a 10-12
font typewritten line, 1/3” for two typewritten lines and 1” for general corrections.
Where cover-up tape is used, you must still go over the redacted portion with a black
pen in order to highlight that information has been redacted.
Blacking out. Another solution is to photocopy the original document and use a
black marker pen to block out the sensitive material.
Once redactions have been made on copies of documents, you must ensure that the
redacted text is completely illegible on the final copies to be released. When
redacting by hand with a black marker pen the best approach to take is to scan the
documents on an MFD on the “Black and White” setting. This should ensure that the
text does not show through. However, you should always check that the text is
unreadable before releasing documents.
The reason for undertaking the second photocopy is that information redacted using
marker pen can be read when held up to light.
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Appendix 2
Redaction of electronic records
The following discusses the technical aspects of redacting electronic records.
Issues in redacting electronic records
The redaction of born-digital records is an area of records management practice
which raises unique issues and potential risks.
The simplest type of electronic record to redact is a plain text file. Redacting these
formats is simply a matter of deleting the displayed information - once the file is
saved, the deleted information cannot be recovered.
1.
However, the majority of electronic records created using office systems such
as Microsoft Office may contain significant information which is not displayed
to the user. As a result it is possible that deleted information may be
recovered or simple redaction processes otherwise circumvented.
2.
It is therefore essential that any redaction technique is secured to eliminate
the possibility of redacted information being recovered.
Approaches to electronic redaction
3.
The redaction of electronic records should always be carried out in
accordance with the following principles:
3.1.
The original or master version of an electronic record must never be redacted
– redaction must always be carried out on a new copy of the record, either in
paper or electronic format.
3.2.
Redaction must irreversibly remove the required information from the
redacted copy of the record. The information must be completely removed
from the bit stream, not simply from the displayable record.
3.3.
Electronic redaction should be carried out in a controlled and secure
environment that provides access only to those trained and authorised to
carry out redaction.
3.4.
All intermediary stages of the redaction process should be deleted. Only the
original record and the appropriately redacted copy should be retained.
4.
Electronically redacting documents
4.1.
Traditional redaction
For electronic records, which can be printed as a hardcopy, traditional
redaction techniques, as described in Appendix 1, can be applied. Either the
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record may be printed and redaction carried out on the printed copy, or the
information may be redacted from an electronic copy, which is then printed. If
the redacted copy is required in electronic format, this can be created by
scanning the redacted paper copy into an appropriate format, such as Adobe
Portable Document Format.
5.
Best practice for electronic redaction
5.1.
When redacting electronically, great care must be taken over the choice of
target format. It is crucial that no evidence of redacted information is retained
in a redacted copy. Some formats may allow changes to be reversed
consequently these formats should not be used for creating redacted copies.
5.2.
Redacting PDF documents
Documents already in PDF format should be redacted using the following
steps:
5.3.

An electronic copy is made and this copy is opened in Adobe Acrobat (the
full version, not Adobe Acrobat Reader). For PDF documents where the
text is stored as text, the Text Touch-UP tool can be used in Adobe
Acrobat to replace the redacted text with a redaction marker (e.g.
‘[redacted]’). However, for PDF documents where the text is stored as an
image, the Text Touch-Up tool can’t be used. In these cases, and for
graphics and images, use The Square Tool to redact this PDF by drawing
black rectangles over text and images

The resulting PDF file should be printed off and re-scanned into the
system.
Redacting word-processed documents via electronic means
This guidance applies to word-processed documents, including documents
created using all versions of Microsoft Word, WordPerfect and OpenOffice
Writer.
Office documents should be electronically redacted using the following steps:

An electronic copy is made and information is redacted by selecting the
exempt text and highlighting in black or deleting the exempt information
and replacing it with the text string “[redacted]”, so that redaction is
apparent but the space cannot be used to identify the missing information

The document should then be scanned to produce a PDF. N.B. You
should not ‘printed to PDF’ or convert to PDF via your computer software.
Converting redacted documents in this makes it possible for the recipient
of the information to undo the conversion enabling them to reveal the
unredacted version.
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5.4.
Redacting spreadsheets
This guidance applies to electronic spreadsheets, including documents
created using all versions of Microsoft Excel, Lotus 1-2-3, and OpenOffice
Calc.
6.

An electronic copy is made and information is redacted by deleting all
restricted information and replacing it with the text string “[redacted]”, so
that redaction is apparent but the space cannot be used to identify the
missing information. The most appropriate method of making an electronic
copy of a spreadsheet file is to export the data to csv format. The redacted
csv version can then be re-imported into a new spreadsheet file.

For spreadsheets containing multiple sheets, each individual sheet will
need to be exported as a separate csv file before it can be redacted. Once
the required data has been redacted, the individual csv files can then be
recombined into a single spreadsheet if required.

It is important to note that if the spreadsheet to be redacted contains
macros, equations, graphs or other similar added content, such items are
not supported in csv files. In this event, the manual redaction method
described below may be more suitable.
Conventional redaction methods
In some circumstances, it may be preferable to redact an electronic office
document by traditional methods, rather than electronically.
This guidance applies to word-processed documents and spreadsheet files as
described above.
Documents should be redacted using the following steps:
Either:
The document should be printed to paper

The paper copy should be redacted using conventional methods for
redacting paper records

If an electronic version of the redacted document is required, this should
be created by scanning the redacted paper copy into an appropriate
format, such as Adobe Portable Document Format
Or:

An electronic copy is made, this copy is redacted by deleting all restricted
information and replacing it with the text string “[redacted]”, so that
11
redaction is apparent but the space cannot be used to identify the missing
information
7.

The redacted document is then printed to paper

If an electronic version of the redacted document is required, this should
be created by scanning the redacted paper copy into an appropriate
format, such as Adobe Portable Document Format
When redacting electronic formats, a record of decisions should be kept in the
same way as with paper formats. See Appendix 3
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Appendix 3
Sample of simple form for recording redaction decisions
Date of
redaction
Folio
Document
reference
Details of
exempt
material
Paragraph
Exemption
applied
Justification
for
exemption
From
(inclusive)
Line
Reviewer’s
comments
Any other
comment
To (inclusive)
Example of form to record decisions and pass on information to document editors
carrying out redaction
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