Employers quite often refuse to disclose documents that mention or relate to other individuals, saying they have to keep those documents confidential because of the…
Lots of employment tribunal cases are won or lost depending on how thorough a job the claimant has done of shaking all the relevant documents…
There is now a useful discussion of privilege, including waiver (see previous post), by the President of the EAT in Howes v Hinckley Bosworth BC
Don’t ever assume that disclosure is completed. One particular point at which to reconsider whether the respondent has disclosed all the documents it ought to have is when you first read its witness statements.
If you want the other side to do something (e.g. disclose some documents to you), always see if they will do it voluntarily before you apply for a tribunal order requiring them to do it.