I certainly agree with your presentation that fax numbers and emails should not be considered personal information, but again, I'd welcome the CMA's view on that.
In terms of fact-finding being part of the formal dispute resolution process, that is, whether it's accessible by employees, I can understand your argument that this could make witnesses reluctant to come forward with information, because it would be disclosed and they would be on record and could be subject to lawsuits, I assume. On the other hand, if I'm an employee and I've been accused of some heinous act, and management has this in their records, wouldn't I want a chance to know that it's there, and shouldn't I have a right to refute it? It could affect my entire working relationship with the company.