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12.
13.
14.
5.
relation to further retention applications, it may not be as successful in respect of SARG concerns. Nor would this approach provide a guarantee of protection to records not yet 30 years old at the time of their transfer to
Future applications for such records would be made by FCO without direct input from Hong Kong. Again, this supports the case for handling HKG records as an exception.
UK.
The criteria for extended closure (Para 5.3.2, sub- sections (a) and (c)) appear to be tailor made' for material in HKG records identified by the review as China sensitive.
It would seem appropriate that a minimum closure period of 50 years from 1997 should be sought (Para 5.3.4) to coincide with the planned life of the SAR under the Joint Declaration. The option to review the length of closure is noted (Paras 5.3.5 and 5.3.6) but HKG might wish to build into the arrangements a no-change clause
this initial period.
this
for
While in principle
process appears straight forward, there are aspects of extended closure that cause disquiet. The physical transfer of sensitive records to the PRO increases the risk of their release to the public and of knowledge of the sensitivity review getting out. Not to put too fine a point on it, how secure is the PRO and its staff? Secondly applications must include 'a clear description of the sensitivity' (Para 5.3.9) and require both submission to the Advisory Council, albeit in summary form, (Para 5.1.10) and the posting of the Instrument and Schedules in the PRO for public inspection (Para 5.1.11). I have alluded earlier to the adverse impact of publicity on the PRC and on our on-going records activities here. As they stand, the extended closure procedures are tantamount to a public announcement of the sensitivity review.
These comments have been made mainly in the context of records over 30 years old but any arrangement will have to take account, in advance, of records currently less than 30 years old which would, in the first instance, be retained by FCO. There is also the question of the applicability of the Act and all that we have covered here to categories of records that are being handled
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