Sensitivity review is a mandatory step under the Section 46 Code of Practice and FOIA to ensure records are transferred with clear, documented access decisions that enable PRONI to manage public access appropriately.
What is a Sensitivity Review?
A sensitivity review is the process of identifying information within records that may be exempt from public disclosure under the Freedom of Information Act 2000 (FOIA) or other legislation. Public authorities must complete this review for every record transferring to PRONI, whether the transfer follows a PRONI appraisal or results from a PRONI Permanent Preservation action on your organisation’s retention and disposal schedule.
The review ensures that clear access recommendations accompany each record at the point of transfer, enabling PRONI to manage public access while preserving the integrity and authenticity of the original record.
Why is Sensitivity Review important?
Under the Section 46 Code of Practice on Records Management, public authorities must maintain arrangements for managing access to information throughout its lifecycle, including when records transfer to an archive. This includes providing PRONI with documented access decisions for historical records.
Sensitivity review:
Supports compliance with FOIA and the Public Records Act (NI) 1923.
Ensures transparency and defensible decision-making.
Enables PRONI to apply agreed access status (open or closed) and refer requests appropriately.
When should Sensitivity Review happen?
Sensitivity review must be completed before records transfer to PRONI. Allow sufficient lead time to complete this step as part of your transfer preparations.
Public Authority Actions
Before transferring records to PRONI:
Review each record page-by-page to identify any material that falls under FOIA exemptions or other statutory restrictions.
Do not alter the original record. Recommendations relating to closures or exemptions must be documented, but not physically applied.
Complete a sensitivity review form (PR14H) for each record:
Provide clear, defensible recommendations for each record.
Include exemption references and rationale where required.
Ensure that each form is signed/counter-signed by the Departmental Information Manager or non-departmental equivalent.
Allow sufficient lead time to complete this step as part of the preparations to transfer records to PRONI.
PRONI Actions
On receipt of records PRONI will:
- Review the access recommendations made on the PR14H forms
- Add records to PRONI’s catalogues with their 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
- Digital records transferring to PRONI must also be accompanied by access decisions.