Thankfully the secrecy requirement is no longer a presumed consequence of becoming aware of a disclosure notice. What comfort that actually amounts to remains to be seen. The relevant draft Code of Practice also now requires an authority seeking permission to serve a disclosure notice, so far as is practicable, to establish whether the recipient uses software that gives an automatic warning about key disclosure. If he or she does, the authority must ascertain whether it is reasonable in all the circumstances for the recipient to take steps to prevent this disclosure from happening. The draft Code also requires an authority to seek to establish, again so far as is practicable, the appropriate senior person within an organisation so that that person can be the recipient of the notice rather than some lowly employee.
Ambition carries hidden dangers.
The Bill may be done and dusted, but don't think that's the end of the matter. The communications industry will be looking to exorcise as many demons from the proposed Codes of Practice as possible once the formal consultation process on the guidelines begins.