§ Guide

Completing The Disclosure Review Document A Technical And Legal Guide

This guide, 'Completing the Disclosure Review Document - A Technical and Legal Guide', is for UK lawyers, in-house counsel, and investigators.

Ref · E-D · 2026 · §LIBClass · ConfidentialJuris · England & WalesStatus · Active

Guide · 21 pages · 28 min read · Published 2026-08-29

This guide, 'Completing the Disclosure Review Document - A Technical and Legal Guide', is for UK lawyers, in-house counsel, and investigators. It addresses the process of completing the Disclosure Review Document (DRD), which the guide describes as 'an exam you sit jointly'. The guide covers the anatomy of the DRD, what to learn from the client, your e Discovery specialist, and your forensic examiner. It details field by field who supplies which answer, drafting Section 1, and joint completion and negotiation. Common mistakes, technical limitations, and frequently asked questions are also covered. The guide provides a checklist, red flags, and advice on when to involve a digital forensic expert.

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§ Credit and source

Published by Computer Forensics Lab on 2026-08-29. Original material of the practice, free to read, cite and download. The authority behind this subject is Practice Direction 57AD, Disclosure in the Business and Property Courts, which you should read alongside this guide. See every guide's author and source.

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THE DISCLOSURE REVIEW DOCUMENT · A GUIDE FOR UK LAWYERS Completing the Disclosure Review Document A Technical and Legal Guide COMPUTER FORENSICS LAB DISCOVERY. UK

§ ABOUT THE AUTHOR PREPARED BY COMPUTER FORENSICS LAB E-DISCOVERY TEAM FULL CHAIN-OF-CUSTODY DOCUMENTATION

§ CONTENTS In this guide 01 Executive summary 02 The problem in plain English: an exam you sit jointly 03 Anatomy of the DRD 04 What to learn from the client 05 What to learn from your e Discovery specialist 06 What to learn from your forensic examiner 07 Field by field: who supplies which answer 08 Drafting Section 1 well 09 Joint completion and negotiation 10 The timetable, mapped to the learning 11 Worked example: a Section 2 built from evidence 12 Common mistakes and technical limitations 13 Questions to ask · Suggested wording 14 Checklist and red flags · When to involve a digital forensic expert 15 Frequently asked questions 16 Glossary · References · Disclaimer · How a specialist laboratory can assist

§ 01 · ORIENTATION Executive summary THE HEADLINE POINT: THE DRD IS COMPLETED FROM THREE SOURCES OF KNOWLEDGE, NONE OF THEM THE DRAFTING LAWYER

§ 02 · FIRST PRINCIPLES The problem in plain English: an exam you sit jointly

§ 03 · THE DOCUMENT Anatomy of the DRD FOR THE PRACTITIONER

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§ 04 · SOURCE ON E What to learn from the client

§ 05 · SOURCE TWO What to learn from your e Discovery specialist

§ 06 · SOURCE THREE What to learn from your forensic examiner WHYTHISCONSULTISCHEAPINSURANCE

§ 07 · THEMAP Field by field: who supplies which answer DRD TERRITORY WHO SUPPLIES IT THE EVIDENCE BEHIND THE ENTRY

§ 08 · THE LEGAL HALF Drafting Section 1 well

§ 09 · ACROSS THE TABLE Joint completion and negotiation

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§ 10 · THECLOCK The timetable, mapped to the learning DEADLINE LEARNING THAT MUST ALREADY BE DONE

§ 11 · IN THE WILD Worked example: a Section 2 built from evidence THE ENTRIES, AND WHAT STOOD BEHIND THEM

§ 12 · WHEREITGOESWRONG Common mistakes and technical limitations Common mistakes Technical limitations

§ 13 · INTERROGATORIES & DRAFTING AIDS Questions to ask · Suggested wording Ask your client (before drafting) Ask your opponent Ask your e Discovery / forensic provider SUGGESTED WORDING · INSTRUCTIONTOAPR OV IDERFORTHEDRDSUPPORT PAC K

§ 14 · QUICK CONTROL Checklist and red flags · When to involve a digital forensic expert The DRD completion checklist Red flags When to involve a digital forensic expert

§ 15 · COMMON QUESTIONS Frequently asked questions Who actually completes the DRD? How much detail does Section 2 really need? What if we genuinely do not know a figure yet? The other side's Section 2 is vague. What do we do? Can the DRD be changed after the CMC? Does the DRD bind us at the certificate stage?

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§ 16 · REFERENCE Glossary Sources and authoritative references DISCLAIMER

§ HOW A SPECIALIST LABORATORY CAN ASSIST Working with Computer Forensics Lab Speak to a forensic examiner, not a salesperson. INSTRUCTTHELAB NEWENQUIRIESEMAILE - DISCOVERY

§ Common questions

Frequently asked questions

Who actually completes the DRD?
The lawyer drafts and owns it, but its content is learned: the client supplies the facts about systems, people and retention (confirmed in writing), the e Discovery specialist supplies the measured volumes, tested terms, methods and costs, and the forensic examiner supplies the statements about deleted, irretrievable and special sources. The document is then completed jointly with the other side into one filed version. A DRD completed by any one of those actors alone is deficient in a way opponents can usually detect.
How much detail does Section 2 really need?
Proportionate detail, but evidenced detail: ranges with bases rather than false precision or empty adjectives. A heavy Commercial Court matter warrants an assessment report behind every number; a Less Complex Claim warrants the short form completed from platform reports and a sensible protocol. What no case warrants is an entry nobody could stand behind if asked "how do you know?"
What if we genuinely do not know a figure yet?
Say what is known, state the measurement in progress and the date it will land, and update: "in-place reports indicate [range]; an indexed assessment of the core sources completes on [date] and figures will be exchanged then" is a compliant, credible entry. What is not compliant is a guess dressed as a fact, or a blank held open indefinitely while the timetable runs.
The other side's Section 2 is vague. What do we do?
Request the underlying information in writing (volumes and bases, tested terms, the facts behind irretrievable entries), propose exchange of hit reports, and if vagueness persists put the correspondence before the court: at a Disclosure Guidance Hearing or the CMC, a party with evidence facing a party with adjectives usually gets both its scheme and its costs. The worked example in §11 is the standard shape.
Can the DRD be changed after the CMC?
Yes: it is a working document, and the regime provides for varying disclosure orders as the case develops. Changes are made openly (versioned, reasoned, promptly proposed), typically where pleadings amend, staged tranches trigger, or new sources surface. What damages parties is not change but silent divergence: an exercise that drifted from the filed document without anyone updating it.
Does the DRD bind us at the certificate stage?
Practically, yes: the certificate describes the search actually performed, and the DRD (as ordered and as varied) is the benchmark it is read against. This is the deep reason for completing it from evidence: entries you measured, you can perform and certify; entries you imagined, you must either quietly miss (a certificate problem) or expensively honour (a budget problem). cflab. u k · e-disc ove r y. u k ©2026 Computer Forensics Lab Ltd ·cflab.uk ·e-discovery.uk ·info@cflab.uk ·+44 (0)20 7164 6915 Page 18 of 21
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