Rules and ethics
Part of Corporate communications and UK law: classify the message before applying a rule
A disclosure decision log for corporate communications: what to record
Record each corporate disclosure decision with the question raised, decider, evidence inspected and wording approved, plus corrections and withdrawals.
A disclosure policy says who decides. A decision log shows what was decided, so a correction can be traced later. For every corporate message that touches paid content, claims, market information or personal data, the log keeps one entry written by the named reviewer.
Cedar Vale Engineering Ltd is fictional, and no live message or log test occurred. The entries below are general information rather than legal advice, and a blank field in any entry means the question is unresolved, not that nothing needs recording.
What to take away
- The policy assigns owners; the log records each decision they make.
- Each disclosure gets an entry with the question raised, the decider, the evidence inspected and the exact wording approved.
- Placement, timestamp, expiry and the reason for any later change are logged too.
- Every gate carries pass, fail or unresolved, and one failure stops the affected release.
- Keep one log, and let the systems that hold approvals feed it.
What a log entry holds before release
Four fields are written at the moment of decision: the question raised, the decider, the evidence inspected and the exact wording approved. Together they let a later reader see who decided what, and on which evidence, without reconstructing it from memory.
The wording field is literal. It holds the sentence or label as released, not a description of it, because a correction depends on knowing the exact text that went out. The evidence field names what was actually inspected, such as a screenshot or an insertion order, and not what was merely available.
Field / Entry for a sponsored trade article
- Question raised
- Is the placement paid or controlled content?
- Classification
- Sponsored content
- Decider
- Head of Communications
- Evidence inspected
- Insertion order and screenshot of the placement
- Exact wording approved
- "Paid partnership with Cedar Vale Engineering Ltd"
Here Cedar Vale pays a trade publication for a sponsored article on its new pump range and controls the copy. The policy owner classifies the real item, using advertising checks. A supplied quote or newsroom post does not prove independent endorsement, and CAP Code Section 2 requires marketing communications within its non-broadcast remit to be recognisable.
Classify paid or controlled material
Who pays, benefits or controls placement?
Mark advertising, name reviewer, add identifier
Record independent editorial boundary
Which rule applies to an item is a separate question, covered in the legal classification guide. The log only records the answer the reviewer reached and the evidence behind it.
What is logged after release
After release, log the placement, the timestamp, the expiry and the reason for any later change. These items turn a one-off approval into a history, which is what a correction or a complaint needs.
Keep rejected versions if lawful and necessary to trace corrections. Store them without republishing confidential or personal data, and trim a stored copy to what the trace needs. A short note on why a version was rejected lets the reasoning survive beside the decision.
Pass, fail or unresolved
Every gate in the entry takes one of three statuses: pass, fail or unresolved. Any failure stops the affected release. Publication stays on hold until named reviewers complete the fields, check the live source status and approve only the defined communication.
Gates cover legal, factual, employment, market, advertising, consumer, privacy, IP, accessibility, security and sector questions. A blank field is unresolved, and the log shows it as open until a named reviewer closes it. The table shows who signs each kind of entry, using typical owners for these fields.
Gate / Who signs the entry
- Paid, controlled and independent material
- Head of Communications and Advertising Compliance Lead
- Claims, interests and source authority
- Head of Communications, Data Protection Lead and General Counsel
- Market and formal disclosure
- Head of Investor Relations, Company Secretary and General Counsel
- Data, accessibility and security
- Data Protection Lead, Head of Security and Accessibility Lead
- Correction and withdrawal
- Policy Owner, Head of Communications and General Counsel
Entries for market and formal disclosure
A market entry records whether an issuer, instrument or formal recipient is in scope, whether the information is potentially inside or confidential, and who is authorised to release it. The route and timing are logged, as is any action taken after a leak or premature publication.
The FCA Handbook DTR 2 addresses disclosure and control of inside information by issuers within scope. The communications team must not infer applicability or use a general press route in place of an authorised market announcement, so the entry names the authorised owner.
Entries for corrections and withdrawals
A correction entry points back to the original, so nobody edits history quietly. It records the authoritative version and archive, the person who can pause release, the correction trigger and its approver, and the channels and recipients to update.
Log the complaint or challenge route and the withdrawal steps too, including evidence retention and reissue. When a later change alters wording that was approved, add a new entry with the reason rather than overwriting the first, so the approved text and the corrected text sit side by side.
A security-incident entry cites the NCSC incident communications guidance, which advises providing accurate information about the impact and avoiding anything that may have to be retracted later. It does not replace a legal notification analysis, so the entry names that owner too.
Where the log lives
Keep one source of truth for the log and map each gate to the system that already holds its approval. Content sign-off may sit in the CMS, market announcements in the IR workflow and data requests in the privacy tool.
The log records the owner, timestamp and evidence without duplicating those approvals. A reference to the approving system is enough, which keeps the log short and stops two records drifting apart. The quality gates a message passes before release feed the same entry.
Before you act
- Open one entry per disclosure and complete the four pre-release fields.
- Log placement, timestamp and expiry after release.
- Give every gate a pass, fail or unresolved status.
- Record the reason for any later change as a new entry.
- Check live source status and approve only the defined communication.
Common questions
What does a completed entry look like?
The Cedar Vale table above shows one paid placement with the question, classification, decider, evidence and exact label filled in.
Is the log the same as the policy?
No. The policy assigns each decision to a named owner. The log records the decisions those owners make, one entry per disclosure.
Does a blank field mean nothing needs recording?
No. A blank field is unresolved, not permission to omit information, and the release stays on hold until a named reviewer completes it.
