Although my focus of records management is rooted in health information, you are justified in your concerns. The public has an expectation that entities utilizing personally identifiable information maintain it within generally acceptable standards of practice. All records management guidelines have a "theme" that applies to health records, government records, as well as corporate records in that the following should be in place: Administrative safeguards that address risk analysis, contingency planning and incident procedures; technical safeguards addressing access control, audit controls, and authentication; and physical safeguards regarding device/media controls, facility access controls and work station use/security. Somewhere under the auspices of the administrative safeguards, policies should be in place to address internal as well as external handling of records throughout the entire lifecycle of a record (creation to destruction). I question whether he is going against a records management/disposition policy that is already in place, HOWEVER regardless of whether a policy is in place or not this obviously creates an ethical dilemma. While it may be "legal" to handle records disposition as the Sheriff has announced (however further research would need to be done to determine this or not), it is certainly not ethical. Donna S. Hoover, MBA, RHIA Records Management Services Woodrow Wilson Rehabilitation Center HIPAA Privacy/FOIA Officer PO BOX 1500, W-484 Fishersville, VA 22939-1500 Ph: 540.332.7904 Fx: 540.332.7923 -----Original Message----- From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Harrington, Richard Sent: Monday, February 23, 2009 9:20 AM To: [log in to unmask] Subject: Re: VA Shredding by inmates??? I've mixed feelings about this type of work. The State Correction department had issues with inmates microfilming documents and some of them involved private information being leaked to the defendant in a court case. This could happen just as easily with shredding, even if the inmate is being watched. In addition, you are then using two persons to do the job of one even if only one is being paid. I'm also not certain if using inmates would meet HIPPA or DOD requirements. Fairfax had employed inmates to do shredding, but I discontinued it because of our volume. They could not keep up with the amount of records needing to be shredded. We average about 600 to 800 boxes per month. Last year the County shredded over 180 tons of paper, and the school system had close to the same amount. At the moment, we are using a vendor for shredding which was done through a requisition. We recently issued an RFP which should be awarded by the end of this month. Under the RFP, the vendor will provide shredding for our records at the records center, but also provide on-site shredding at the various departments, special shredding on various days throughout the year that the County provides shredding services for residents, and special secure pickup containers for shredding at designated locations. Richard "Dick" Harrington County Archivist / Recs. Mgr. Fairfax County Archives & Records 6800-A Industrial Rd. Springfield, VA 22151 Tel: 703 658-3776 Fax: 703 642-2832 -----Original Message----- From: Virginia Records Officer's Listserv [mailto:[log in to unmask]] On Behalf Of Lois Reeves Sent: Friday, February 20, 2009 11:55 AM To: [log in to unmask] Subject: VA Shredding by inmates??? As a Records Manager and VA Beach taxpayer, I am not happy about the recent revelation that Sheriff Lateigne is planning to use inmates to shred city documents. A. Those might include my personal documents. B. I can think of better uses of taxpayer money during a budget deficit. C. Risk and legality issues come to mind. I think it was a very short-sighted and ill-concieved idea. Sheriff Lateigne did not contact his own Records Management department for comment or LVA. I doubt he's aware of the many laws and regulations governing our records. Please read the article and comments at: http://hamptonroads.com/2009/02/va-beach-sheriff-plans-use-inmates-shred - city-papers I would like some feedback on this. 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