Yes, said the United Kingdom Court of Appeal in the recent case of Fairstar Heavy Transport NVv Adkins & Anor [2013] EWCA Civ 886 where it considered whether a company could require its former CEO to give it access to the content of emails relating to the company's business affairs stored on his personal computer.

The Court of Appeal confirmed that Adkins had been an agent of Fairstar and, as Fairstar's former agent, had a duty to allow it to inspect documents (both paper and electronic) sent to or received by him and relating to its business. The termination of the relationship between the parties did not terminate the duty binding on Mr Adkins to make these documents available. Of course, the parties might have avoided court if there had been a formal employment agreement in place.