Guide
The Electronic Discovery Reference Model For UK Litigation Teams
24 pages · 31 min read
The Electronic Discovery Reference Model (EDRM) provides a structured approach to electronic disclosure in UK litigation.
- Electronic disclosure practice
§ Guide
The Electronic Discovery Reference Model For UK Litigation Teams
This guide explains the Electronic Discovery Reference Model, showing how it maps onto English disclosure through a worked commercial dispute.
Ref · E-D · 2026 · §LIBClass · ConfidentialJuris · England & WalesStatus · Active
Guide · 24 pages · 31 min read · Published 2026-08-29
Navigating electronic disclosure in English commercial litigation requires aligning procedural duties with technical forensic precision. Designed for UK solicitors, barristers, and litigation support professionals, this reference details the technical stages of the Electronic Discovery Reference Model, mapping identification through to production directly onto English disclosure practices. Using the worked commercial dispute Halworth v Brydon, the text demonstrates how data volume reduces across the processing funnel while preserving strict chain of custody under ACPO and NPCC digital evidence principles. It covers key operational considerations including Relativity-ready hosted review, Disclosure Review Document specifications, and CPR Part 35 expert report preparation, alongside cross-cutting obligations surrounding privilege, data protection, integrity, and proportionality. Legal teams receive practical drafting aids for protocols and instructions, checklists for critical checkpoints, and interrogatories for clients, opponents, and e-discovery providers. By addressing common technical limitations, red flags, and the precise point at which to instruct a digital forensic examiner, the material enables legal teams to avoid procedural oversights and deliver defensible, cost-effective disclosure workflows.
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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 EDRM, the Electronic Discovery Reference Model, which you should read alongside this guide. See every guide's author and source.
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Page 1
THEEDRMEXPLAINED · A GUIDE FOR UK LAWYERS The Electronic Discovery Reference Model for UK Litigation Teams Identification to Production, Through a Worked Commercial Dispute COMPUTER FORENSICS LAB DISCOVERY. UK
§ ABOUT THE AUTHOR PREPARED BY COMPUTER FORENSICS LAB E-DISCOVERY TEAM ACPO / NPCC DIGITAL EVIDENCE PRINCIPLES RELATIVIT Y-READY HOSTED REVIEW CPR PART 35 EXPERT REPORT S FULL CHAIN-OF-CUSTODY DOCUMENTATION
§ CONTENTS In this guide 01 Executive summary 02 What the EDRM is, and how it maps onto English disclosure 03 The worked example: Halworth v Brydon 04 Stage 1 · Identification 05 Stage 2 · Preservation 06 Stage 3 · Collection 07 Stage 4 · Processing: what actually happens to evidence between collection and production 08 Stage 5 · Review 09 Stage 6 · Analysis 10 Stage 7 · Production 11 The funnel in numbers: Halworth v Brydon end to end 12 Integrity, privilege, data protection and proportionality across the model 13 Common mistakes and technical limitations 14 Questions to ask: client, opponent, provider 15 Suggested wording for instructions 16 Checklist and red flags 17 When to involve a digital forensic expert · FAQ 18 Glossary · References · Disclaimer · How a specialist laboratory can assist
§ 01 · ORIENTATION Executive summary
§ 02 · THEMAP What the EDRM is, and how it maps onto English disclosure INFO. IDENTIFICATION PRESERVATION COLLECTION PROCESSING REVIEW ANALYSIS PRODUCTION PRE GOVERNANCE
§ 03 · THECASE The worked example: Halworth v Brydon SYSTEM / SOURCE WHAT IT HOLD S FIRST-WEEK STATUS
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§ 04 · STAGE1 Identification HALWORTHVBRYDON · IDENTIFICATION
§ 05 · STAGE2 Preservation HALWORTHVBRYDON · PRESERVATION
§ 06 · STAGE3 Collection HALWORTHVBRYDON · COLLECTION
§ 07 · STAGE4 Processing: what actually happens to evidence between collection and production THEPRINCIPLETHATMAKESTHEFUNNELDEFENSIBLE HALWORTHVBRYDON · PROCESSING
§ 08 · STAGE5 Review HALWORTHVBRYDON · REVIEW
§ 09 · STAGE6 Analysis HALWORTHVBRYDON · ANALYSIS
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§ 10 · STAGE7 Production HALWORTHVBRYDON · PRODUCTION
§ 11 · THE NUMBER S The funnel in numbers: Halworth v Brydon end to end STAGE ITEMS IN ITEMS OUT WHAT CHANGED, AND WHERE THE (ACTIVE) EXCLUDED ITEMS ARE
§ 12 · CROSS - CUTTINGDUTIES Integrity, privilege, data protection and proportionality across the model
§ 13 · WHEREITGOESWRONG Common mistakes and technical limitations Common mistakes across the model Technical limitations to understand
§ 14 · INTERROGATORIES Questions to ask Ask your client Ask your opponent (through the DRD and correspondence) Ask an e Discovery provider
§ 15 · DRAFTING AIDS Suggested wording for instructions PROCESSING PROTOCOL ( COREOPER AT IVE PA R AG RAPHS ) PRODUCTIONSPECIFIC AT ION ( FOR THE DRD ) WEEK LY CHECKPOINTREPORTING ( PROVIDER INSTRUCTION )
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§ 16 · QUICK CONTROL Checklist and red flags The EDRM checkpoint checklist Red flags
§ 17 · ESCALATION & COMMON QUESTIONS When to involve a digital forensic expert Frequently asked questions What actually happens to evidence between collection and production? Is the EDRM binding in England & Wales? Do small cases need all seven stages? Why was only a fraction of the population ever read by a lawyer? Who owns each stage, us or the provider? What happens to the data after the case?
§ 18 · REFERENCE Glossary CAL DRD EDRM 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
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