Active Members on Council, Committees and staff have access to ICAEW information in accordance with the following principles:

1. Individuals may have access to information provided this is both relevant and necessary to perform their role. In the case of staff, relevance is determined by the line manager. In the case of Active Members on Council and Committees, the President will make any final determination following consultation with the Chair of Council and the Chief Executive.
2. Access is restricted where necessary due to the following circumstances:
   • Personal information and data may only be used in accordance with the terms for which it was supplied. This is a requirement of the Data Protection Act.
   • Data and information on member firms is not shared where that information is considered to be commercially sensitive to the firm.
   • Information collected or produced as part of a quality assurance review, complaint or disciplinary case against an individual member or member firm.
   • Information provided as part of a contractual arrangement that includes clauses on confidentiality or non-disclosure cannot be shared outside of that agreed in the relevant terms.
   • Information shared by a third party e.g. government or regulator, where retaining confidentiality was stipulated at the point of sharing or exchange.
   • Details of any legal opinion obtained by ICAEW will not be shared where disclosure could mean the right of legal privilege will be lost.
   • If responding to a request would place an unreasonable burden on ICAEW resources at the expense of other activities.
   • Minutes may be restricted due to commercial sensitivities.
   • Any other matter that the President, Chief Executive or Chair of Council may determine.
   If any request cannot be fulfilled due to these restrictions, the reason(s) why will be clearly communicated.
3. Information requests should be clear about what the true purpose of the request is to ensure that the information provided is appropriate and complete. This should include clarification of how the information is proposed to be used.
4. Due respect will be given to the appropriate Board or Committee responsible for an ICAEW activity in line with the delegations set out in the Charter, the bye-laws and the individual Committee Terms of Reference as approved by Council. In practice this means that a concern about how an activity is being operated should be raised through the appropriate Committee Chair to allow the relevant Committee to fulfill its responsibilities and be accountable for the outcome.
5. Information provided is confidential to ICAEW and the person to whom it is provided. This information may not be shared unless explicitly agreed.