Sensitivity Reviews of Digital Records

The principles for sensitivity review are the same for digital and paper records. Public Authorities must identify information that may be exempt from public disclosure under the Freedom of Information Act 2000 (FOIA) or other legislation and provide clear access recommendations at the point of transferring records to PRONI.

For full details on why sensitivity review is required and its role in legislative compliance, see our guidance on Sensitivity Reviews of Hardcopy Records.

This page explains the additional requirements when sensitivity review and access decisions need to be provided for digital records.

 

How is Sensitivity Review Different for Digital Records?

While the purpose and timing of sensitivity review remain the same, the way recommendations are recorded differs. For digital records:

  • Recommendations should be captured in a csv spreadsheet, not on a paper form.
  • Each record included in the transfer must have its own row with specific fields.

 

Public Authority Actions

Complete sensitivity review for each digital record and include the following fields in a csv spreadsheet:

  1. Access Status: Open or Closed.
  2. FOIA Exemption: The precise exemption (e.g., s.40 Personal Data) must be stated if the Access Status is Closed.
  3. Public Interest Test (PIT): Either include PIT outcome or provide a link to a document with expanded detail.
  4. Next Action: Based on FOIA exemption (e.g., “Open in” if exemption falls away automatically, or “Review in” if it does not).
  5. Year for Next Action.
  6. Reviewer Name: the person within your organisation who has reviewed the record.
  7. Date of Recommendation.
  8. Countersignature: Departmental Information Manager or equivalent should countersign to confirm that they agree with the Reviewer’s recommendation.
  9. Date of Countersignature.

Note that fields 2 to 5 will be blank if the Access Status is Open.

Ensure all records are finalised and ready for transfer before completing sensitivity review. Allow sufficient lead time for this process.

 

PRONI Actions

On receipt of records, PRONI will:

  • Review the access recommendations provided in the spreadsheet.
  • Add records to PRONI’s catalogues with agreed access decisions, which determine the level of public access.

Important Notes: 

  • Section 66 FOIA: Closed records remain subject to FOIA and other access legislation. PRONI will refer requests for access to closed records back to the Responsible Authority.
  • Sensitivity and FOIA exemptions can change over time. PRONI may contact public authorities to review or update recommendations.

Related Guidance