Checklist: How to avoid an accidental breach when redacting documents
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Due to the Data (Use and Access) Act coming into law on 19 June 2025, this guidance is under review and may be subject to change. The Plans for new and updated guidance page will tell you about which guidance will be updated and when this will happen.
You are responsible for complying with your obligations under the UK GDPR and Data Protection Act 2018 (DPA 2018) and, where relevant, other information rights legislation, including the Freedom of Information Act 2000 (FOIA). Whilst we make every effort to make sure this guidance is accurate at the time of publication (31 July 2025), we make no guarantees or representations that it will remain up-to-date or ensure compliance. Where appropriate, seek further guidance or advice before disclosing information in the specific circumstances. If you would like to suggest improvements to this guidance, please leave us feedback.
Steps you must take:
☐ We have appropriate data protection policies and procedures to help staff redact documents securely and respond to breaches effectively.
☐ We keep personal information secure, including maintaining the integrity of our records and using appropriate methods (eg passwords and secure redaction techniques).
☐ We comply with relevant obligations under information access and data protection legislation if we need to remove personal information from a document or consider an appropriate format in which to disclose it.
Steps you should take:
☐ We give staff appropriate data protection training about redacting documents securely and how to report breaches, including induction and regular refresher training.
☐ We make sure that all redaction is undertaken, or overseen, by staff trained to redact information securely and consistently in line with appropriate policies and procedures.
☐ We make sure that if staff give instructions about redacting information, including what information to redact, these are clear and precise.
☐ We avoid indicating what information to redact by completely covering the text (eg with black marker), so staff do not mistakenly believe it is the version to disclose.
☐ We only redact from a copy of the document, not the original.
☐ We check documents appropriately before disclosing them, considering the circumstances, including the risk of harm if personal information was accidentally disclosed.
☐ We know how to remove personal information that cannot be disclosed and redact it effectively (see also redaction checklist below).
☐ We avoid using ineffective techniques to redact information. For example, we don’t:
- use black marker on hardcopy documents without photocopying or scanning a copy for disclosure;
- cover information in electronic documents with black rectangles and leaving the text underneath; or
- use simple image editing tools.
☐ We keep a record of our decision to redact information from a document so that it is clear who redacted the information, when and why.
☐ We keep a clearly labelled copy of the redacted and unredacted version of the document for as long as it is needed.
Steps you could take:
☐ We raise awareness within our organisation about the risks of redacting documents ineffectively.
☐ We review redactions (or a sample, if appropriate) to check they are effective (eg peer review or senior review).
☐ We disclose a photocopy or a scanned copy of redacted hardcopy information.
☐ We use redaction software to redact information securely from electronic documents, if available.
☐ We use roundtrip redaction techniques to redact information securely if we do not have redaction software or want to use an alternative method. For example:
- Convert a redacted Word or Powerpoint saved in pdf format to a simple image format (eg Windows BMP), and back to pdf.
- Convert an Excel spreadsheet to csv format and back to a new Excel spreadsheet.
- Redact a pdf using Adobe tools (eg Text touch up tool or Square tool), converting it to a simple image format and back to pdf.
☐ We use appropriate tools and secure techniques to redact information from still images effectively, such as photographs. For example, masking information by obscuring part of an image with a solid block of colour and then exporting the redacted image to a simple image file format (eg png or jpeg).