Avoid routine deletion

Once a dispute is reasonably anticipated, ordinary deletion or destruction of potentially relevant records may create practical and evidential difficulties. Relevant personnel should be told to preserve documents within their control.

Identify the likely sources

Evidence may be stored in email, messaging applications, cloud drives, accounting systems, mobile devices, physical files, CCTV systems or records held by third parties. The likely sources will vary by matter.

Keep original context

Screenshots can be useful, but they may omit metadata, surrounding messages or attachments. Where possible, retain original files, full conversation exports and information showing dates, senders and recipients.

Use an organised structure

Documents can be grouped by topic and date, with a separate index for key items. A working chronology and document list often make later review more efficient.

Protect confidentiality

Collection and transfer of documents should take account of confidentiality, personal data, access controls and any legal restrictions. Sensitive material should not be circulated more widely than necessary.


The appropriate steps depend on the facts, documents, procedural position and current law. Specific advice should be obtained before action is taken.