Redactions policy

Specifically, this policy outlines how Scottish Forestry (SF) handles redactions when publishing or disclosing information whilst undertaking our tasks as outlined:

• in our SF Privacy Notices
• under the Freedom of Information (Scotland) Act 2002 (FOISA)
• under the Environmental Information (Scotland) Regulations 2004 (EIRs)
• other relevant legislation

It does not supersede our duties under FOI / EIR legislation.

It ensures that we balance transparency with our legal obligations to protect personal data, sensitive information, and third-party rights.

Scottish Forestry are delivering, on behalf of Scottish Ministers, the powers and functions conferred on Ministers in the Forestry and Land Management (Scotland) Act 2018.

This is focused on promoting and supporting sustainable forest management. As a public authority, we are committed to openness and accountability in how we deliver these services.

Redaction is a term used to describe the editing process whereby information is removed from a document. It is a process which is undertaken to render information unreadable.

This is done by blocking out individual words, sentences and paragraphs or by removing whole pages or sections prior to the release of the document.

We may redact sections of documents before publication or disclosure to:

• protect personal data under the UK GDPR and Data Protection Act 2018
• comply with legal exemptions under FOISA and exceptions under EIRs
• respect third-party intellectual property rights
• prevent disclosure of information that could prejudice law enforcement, commercial interests, or the environment

SF will redact information where disclosure would breach legal obligations or compromise legitimate interests.

This includes, but is not limited to:

• personal telephone numbers including mobile phone numbers (excluding commercial or business phone numbers)
• personal email addresses (excluding commercial or business email addresses) or email addresses nominated as the main contact point for business entities undertaking grants, loans and/or regulatory permissions
• faces in photographs and/or images
• wet or electronic handwritten signatures and other identifiers
• special category data as defined under UK GDPR, e.g. health, biometric, racial/ethnic data
• personal financial information, for example bank statements
• data that could lead to environmental harm if misused
• protected and sensitive species information
• Scottish Forestry’s commercial confidentiality (and any items marked as confidential by the sender)
• legal and security concerns
• legal advice protected by privilege
• internal deliberations where premature disclosure could inhibit decision making
• copyrighted material
• exemptions under FOISA and exceptions under EIRs
• details of any criminal investigations or convictions

We will not redact information unless there is a clear and lawful reason to do so.

This list is not exhaustive, the following are examples of what we will not redact:

• information under Section 4 where it has been provided to us, unredacted, from an agent acting on another person's mandate
• commercial contact details (telephone, mobile phone, email, etc.)
• publicly available information, including data already published on our and others’ websites or in public registers
• information disclosed in previous FOI/EIR responses
• non-personal operational data (unless you have told us it is commercially sensitive)
• policy documents and strategic plans
• minutes of meetings (with personal data removed)
• financial transparency
• where SF holds copyright and there are no legal restrictions
• addresses
• stock images related financial, business and operational information unless stated to be confidential
• electronic [typed] signatures (unless wet or handwritten)
• initials

To reduce redaction requirements on Scottish Forestry any supporting document relating to case work must be provided in line with recommendations.

Where a provided document is not in line, Scottish Forestry reserves the right to request the applicant to make changes and resubmit the documents.

We follow the Scottish Information Commissioner’s and where applicable the UK Information Commissioners Office guidance, on our duties to make information available.

Scottish Information Commissioner (external website)

UK Information Commissioners Office (external website)