Protecting Records on the Road
In 2008, a courier transporting hospital records to a Utah storage facility left the files in a company vehicle overnight. Thieves broke in and helped themselves to its contents — including computer tapes with the personal billing information of 1.5 million patients. Although the records were recovered within a month, with no sign that the files had been accessed, the damage was done. By late 2010, the hospital had shelled out $3.4 million in credit checks, legal fees, and other costs, angered millions of patients and faced ongoing litigation.
Transporting files to an offsite location — across town, across states, and around the world – involves much more than tossing boxes on a truck. Factors to consider include security, legal issues, regulatory compliance, and documentation.
Here are some guidelines for transporting records safely:
- Clean house. Relocating files presents a great opportunity to apply records retention schedules to make certain unnecessary records are earmarked and properly destroyed. It’s also a chance to look into the possibility of digitizing some of your files.
- Know what is being moved and why. Vital records should be identified and clearly labeled for easy, secure storage, and retrieval at their new home. If your organization has a policy for moving records, be sure to follow it. And, in any case, it’s wise to document the process so you can prove compliance.
- Use the right tools. Pack the files in sturdy containers — ideally the receptacles in which they will be stored long-term — and label them clearly. Specially made cardboard boxes are commonly used, but there are other containers available, including purpose-made boxes and storage bins with security seals. If many boxes are involved, place them on pallets and shrink-wrap them to avoid damage during shipping. The transporting vehicle should be adequate for the job, securely sealed and, if possible, sent directly to the storage facility.
- Ensure security at every step. If outside couriers or shipping services are involved, make sure their security measures are robust and followed flawlessly. This is especially important if records are transferred between contractor vehicles, such as between different trucks or between trucks and cargo planes.
- Demand chain-of-custody documentation. This may be required for certain legal and regulatory files. Make sure you have a way to track the delivery at every step along the way. Records in transport shouldn’t ever be left unattended on loading docks or in unsecured vehicles.
- Follow the rules. Regulations have become increasingly stringent, especially when it comes to managing records containing personal information. In the health care industry, for example, HIPAA and the more recent HITECH Act set forth detailed rules for records privacy and security — with heavy penalties for failure to follow them. Other regulatory agencies around the world, from the FDA to Europe’s EMEA, give guidance on managing sensitive records. For overseas shipping, there may be unique country-by-country requirements you need to know and follow. Wherever your files go, make sure they are leaving in compliance with any applicable regulatory agency’s guidelines. Note that these rules impact every aspect of the movement, accessibility, and protection of those records. Understand how these regulations apply to the records you’re moving, and take steps to meet those standards. Finally, have the documentation to prove it.
With serious planning and a solid commitment to security and relevant rules, moving day can be a successful experience — and your records will be safe and sound in their new home.
# # #
Abraxas understands the security, privacy, and regulatory challenges involved in transporting records — and can help you make a move with confidence. We provide clients with tailored records and information management solutions, delivering the business intelligence that matters most — and we do it more efficiently and reliably than anyone else, particularly in highly regulated industries. To learn more, email firstname.lastname@example.org or call us: 866.535.0016 (toll-free) or 269.226.0016.