Preserving, identifying, retrieving and reviewing relevant documentation is likely to be the most time-consuming element of any internal investigation. What steps need to be taken to ensure that documents, storage and search records, trade data and other relevant information is preserved? What methods and technology can the company use to collate the documentation? Adopting a structured and proportionate approach will be essential. Most importantly, the company will need to carefully consider data protection and privacy issues, particularly (but not only) when gathering information across multiple jurisdictions.

The Panel will consider data protection and privacy issues in the context of the preservation and collation of documents as part of the internal investigation.