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PRODUCTION PROTOCOL S · A GUIDE FOR UK LAWYERS How to Draft an Electronic Disclosure Production Protocol The Agreement That Decides Every Later Argument, Clause by Clause COMPUTER FORENSICS LAB

§ ABOUT THE AUTHOR PREPARED BY COMPUTER FORENSICS LAB E-DISCOVERY TEAM ESTABLISHED 2007 · LONDON ISO 17025-ALIGNED PROCEDURES FULL CHAIN-OF-CUSTODY DOCUMENTATION

§ CONTENTS In this guide 01 Executive summary 02 The problem in plain English: the argument you have now or the ten you have later 03 Where the protocol sits: the DRD, PD 57AD and when to agree it 04 The format clauses: natives, images, and the per-type schedule 05 The data clauses: metadata fields, families, threading and load files 06 The protection clauses: redaction, privilege, clawback and confidential it y 07 The operations clauses: exchange, tranches, corrections and disputes 08 Source architecture: where else the evidence lives 09 Worked examples 10 Common mistakes and technical limitations 11 Questions to ask · Suggested wording 12 Checklist and red flags · When to involve a digital forensic expert 13 Frequently asked questions 14 Glossary · References · Disclaimer · How a specialist laboratory can assist

§ 01 · ORIENTATION Executive summary THE HEADLINE POINT: APRODUCTIONPROTOCOLISTHECHEAP, EARLY AGREEMENT THATPREVENTSTHEEXPENSIVE, LATEDISPUTES: DRAFTITWITHTHEENGINEERSIN THEROOM, TESTITAGAINSTTHEKNOWNDISASTERS, ANDAGREEITBEFORETHEFIRST TRANCHEISBUILT

§ 02 · FIRST PRINCIPLES The problem in plain English: the argument you have now or the ten you have later

§ 03 · THEFRAME Where the protocol sits: the DRD, PD 57AD and when to agree it