Internal BPD Handling Arrangements
60. In addition to the published BPD Handling Arrangements, GCHQ, MI5 and
SIS have their own internal BPD Handling Arrangements, which were also in
force from 4 November 2015. Gisted versions of these are in evidence. These
reflect and supplement the published BPD Handling Arrangements. They are
not separately set out in detail here.

GCHQ Compliance Guide
61. The relevant sections of the GCHQ Compliance Guide have been set out in
evidence.
MI5 internal arrangements
62. MI5 continues to have internal guidance in addition to the BPD Handling
Arrangements. In particular:
(a) In November 2015 MI5 updated its internal BPD Guidance (in evidence).
That sits alongside the internal MI5 Handling Arrangements (also in
evidence).
(b) An MI5-specific version of the SIA BPD Policy was used from November
2015, as produced in evidence.
(c) A new version of the Form for Retention began to be used in May 2016, as
produced in evidence.
SIS internal arrangements
63. SIS also continued to have additional internal arrangements, as disclosed in
evidence.
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