An internal memo has been sent to European Union officials warning them to be careful about what information they commit to paper. The advice was issued in advance of new rules that will give the public greater access to European commission documents.

The 15-page memo tells Eurocrats not to make references to lunching or drinking with lobbyists, to “avoid recording statements which may turn out to be politically embarrassing for those who have made them” and to draft all documents with the utmost care, “bearing in mind that they may be made public at some point”.

The handbook, seen by The Sunday Times, was circulated in January to the directorate-general for trade (DG Trade), one of the EU’s most important policy areas. It repeatedly reminds officials that all their documents may be subject to public disclosure. “This is particularly the case for meeting reports and e-mails with third parties (eg industry) which are favourite ‘targets’ of requests for access to documents,” it said.

It asks officials to avoid making any references to informal meetings or contacts they have had, such as meals or drinks with lobbyists. “Don’t refer to the great lunch you have had with an industry representative privately, or add a PS asking if he/she would like to meet for a drink,” it said.

The handbook instructs DG Trade employees to only record “factual elements” when writing a report of a meeting, and warns them not to include “your personal evaluation of the meeting, your opinion on the real intentions of one or more participants, your assessment of the situation, etc”.

To ensure none of these references become subject to disclosure, the handbook advises: “The best thing to do is make two separate documents, ie one factual report and a separate one with the assessment of the report.”

This method would mean officials would not have to “whiten” certain parts of the document to obscure information, if it was requested by a member of the public. This avoids an additional work burden, and also sidesteps the pitfall of people being alerted to the fact that they have not been given access to certain parts of the document, and then taking further action.

That situation, warns the handbook, “always carries a risk of recourse to the ombudsman or the court”.

The document also advises officials how to narrow down the interpretation of a submission for information, so as to release only that which was requested. It gives officials an example of a request for documents concerning meetings with individual companies, which allowed the department to avoid releasing documents about its contacts with business lobbyists.

“Recent cases concern requests for information about meetings with ‘individual companies’ on our FTAs [free trade agreements], which have allowed us to exclude business federations on the same points, or about meetings with ‘DG Trade officials’, which have allowed us to exclude meetings on the same point with the commissioner or the cabinet,” it notes.

Lutz Guellner, a spokesman for the European commission, said allegations that officials had been sent internal instructions to withhold information “are totally unfounded”.

“DG Trade have to comply with EU rules to release documents on request,” he said. “This document was intended as a guideline to raise awareness among employees of the rules, and to help people understand and handle requests. It is 100% clear that no category of any documents are excluded from the rules, and that refusal of all documents can only be made for very specific reasons.”

The transparency regulation dates from 2001 but the commission recently voted on a proposal to overhaul it. Last month MEPs voted in favour of the proposals and a decision is now being taken on the extent to which commercial data can be excused from disclosure. The updated law is expected to be approved in the second half of the year.

In January, P Nikiforos Diamandouros, the European ombudsman, ruled against the commission over its failure to make all documents publicly available. In 2006 Statewatch, a British NGO, claimed the commission was defining public documents in a limited way that meant only those “formally transmitted” were eligible for release.

Times Recommends

• Google to digitise Iraqi artefacts
• Renault angers parents by naming new car Zoé
• Analysis: most lawless part of Philippines