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Taking Michelle's point as a good example: "In our case there are two HR employees included, and in light of the fact that they are acting in a professional capacity advising on employment matters relating to the individual, we considered whether it might be reasonable to include their details, but on balance we felt it might be better to have a consistent approach to all emails. "

Email:

From HR1

To HR2

Re: Fred

Fred is accused of stealing form the biscuit tin.

This is covered by the xyz policy and our approach in such a case is  .... and I recommend we take the following steps.  A B C

End of Email

On the face of it all you have to disclose is that you have an email from HR1 (disclosing the source) to another employee which contains "Fred is accused of stealing form the biscuit tin.". 

The rest is not PD of Fred. 

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