Reputation management disclosure policy: a record template

This blank reputation management disclosure policy is a controlled record, not a standard disclaimer. Complete it for one communication, then take the real evidence and the final placement to your legal adviser and, where relevant, to the ASA, the ICO or the platform route named below. The form is designed for an England operating team. It does not make a review, advert or response lawful.

What to take away

Keeping the record alongside review software

Review and reputation-management software does two jobs. Trustpilot, Reviews.io and Feefo collect and publish customer reviews. Birdeye, Reputation.com, Yext and Uberall manage listings, replies and reputation data across review sites and search results. Google Business Profile, named in the complaint routes below, is the review surface many UK customers see first.

Hold the versioned disclosure and correction record in your own document store, linked to the review or reply it covers, and copy the publication date and the reply back into it. That is what makes the version ID and the six-year retention rule usable when a complaint, a correction or a takedown request arrives.

If you are choosing the software, check four things against this record: a dated audit trail of who approved each reply, roles and permissions for publication, an export you can keep for six years, and a change log that shows what was corrected and when.

Record header

Policy owner: [blank]

Record and version ID: [owner initials]-[YYYY-MM-DD]-v[N] (owner initials, the date of that version and the version number)

Legal publisher and relevant service: [blank]

Final communication, channel and destination: [blank]

Audience, territory and release date: [blank]

Next mandatory review date: [blank]

Retention period: six years from the last publication date (typical default), extended while a complaint, claim or legal hold is open

Version history and approval log: [blank] — add one line per version, giving the version ID, its date, the approver and a short note of what changed

No separate downloadable file is published with this article. The record is plain text here, so copy each field into your own document store and apply the version ID and retention rule.

The owner must retain the finished screen or document, not just the words proposed in a draft.

Review and interest record

Original review, testimonial, endorsement or quotation: [blank]

Source URL, author status and retrieval time: [blank]

Product, service and experience described: [blank]

Payment, gift, discount, free access or other incentive: [blank]

Affiliate, agency, employment, directorship, investment or sponsorship interest: [blank]

Permission and editing boundary: [blank]

Worked example of a completed entry: Payment, gift, discount, free access or other incentive: item supplied free of charge on 2 September 2026, no cash payment and no affiliate commission.

Worked example of disclosure wording for the same entry: Item received free of charge. This review was written voluntarily and no payment was made for it. Adjust the wording to the facts recorded above and log where the label appears in the finished communication.

The Competition and Markets Authority (CMA) guidance for online review sites, published 3 September 2025, calls for clear collection and checking information and disclosure of relevant commercial relationships. Its statutory basis is the Digital Markets, Competition and Consumers Act 2024, which brought fake and misleading reviews into the UK's banned unfair commercial practices. The actual publisher and activity still need classification by counsel.

Claim and placement record

Words proposed for the disclosure: [blank]

Exact location and visual prominence: [blank]

Objective impression created by the whole communication: [blank]

Evidence ID for each factual implication: [blank]

Accessible alternative and tested reading order: [blank]

Advertising reviewer and decision: [blank]

CAP Code section 3 contains current non-broadcast rules on misleading presentation, reviews and testimonials. CAP's advice on testimonials discusses genuineness, permission and material commercial interests. The record must therefore connect any label with source evidence and the finished advert. A hidden or vague declaration cannot be treated as a cure for an unsupported claim.

Complaint and takedown routes

Review-integrity challenge owner: [blank]

Service complaint route: the review platform's own reporting tool, for example Google Business Profile or Trustpilot; the ASA for advertisement claims; the Citizens Advice consumer service for consumer-law complaints

Personal-information rights route: the ICO (Information Commissioner's Office), after a request to the publisher

Defamation and platform-notice escalation: the platform's legal removal channel, such as Google's legal removals process, and the Defamation Act 2013 section 5 procedure

IP notice contact: the platform's intellectual property reporting channel and the UK Intellectual Property Office for guidance

Accessibility help route: the Equality Advisory and Support Service and the service's own accessibility contact

Do not merge these pathways. The Ministry of Justice's Defamation Act section 5 guidance concerns a particular website-operator process in England and Wales, set out in the Defamation Act 2013 (Operators of Websites) Regulations 2013. It does not establish a general right to delete criticism.

Under that procedure a notice of complaint must identify the statement complained of and where it appears. The website operator must then either remove the post or give the complainant the poster's details where the poster consents.

Correction record

Challenged words or data: [blank]

Person raising the issue and verification route: [blank]

Restriction or pause applied, if authorised: [blank]

Decision, reasoning and qualified reviewer: [blank]

Controlled copies changed: [blank]

Recipients or suppliers notified: [blank]

Previous version preserved at: [blank]

The ICO's guidance Right to rectification says a request can be valid without citing Article 16 of the UK GDPR, which sits alongside the Data Protection Act 2018. Privacy counsel must decide the response and whether related restriction, objection, recipient-notification or retention questions arise.

Approval and withdrawal

Consumer-review gate: [pass / fail / unresolved]

Advertising, privacy, PECR, defamation, IP, accessibility, security and contract gates: [record each separately]

Withdrawal authority and contact: [blank]

Copies, campaigns and feeds to stop: [blank]

Evidence that withdrawal or correction completed: [blank]

Reopen triggers: change to source, incentive, relationship, claim, placement, platform, law or regulator guidance [add owner and date]

No gate can compensate for another. Publication remains blocked until every necessary reviewer has supplied a dated decision and the owner has verified the final version.

Before you act

Common questions

What must the policy owner retain after completing the record?

The owner must retain the finished screen or document, not just the words proposed in a draft. This ensures the controlled record reflects the actual communication, not merely the proposed text.

What does the CMA guidance call for regarding online reviews?

The CMA guidance, published 3 September 2025, calls for clear collection and checking information and disclosure of relevant commercial relationships. The actual publisher and activity still need classification by counsel.

When can publication proceed according to the article?

The gate list in Approval and withdrawal controls this. Nothing goes live until the necessary gates pass and the owner has verified the final version.