How, in practice, should reports be written to take account of this new approach?
Where there is considered to be exempt information in a report, decide if it should be placed in a schedule separate to the main body of the report. All that does is physically separate the potentially exempt information into an easily identifiable document.
In the event of a FOIA request being made, the main body of the report can then be disclosed with the exempt schedule being withheld. This will not always be a practical option, particularly where the exempt information forms the majority of the information within the report or where its separation from the rest of a report makes the report meaningless or difficult to interpret or present. In such cases, there may be no alternative to making all of the report exempt.