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Records Management Program <[log in to unmask]>
Date:
Wed, 14 Apr 2010 13:00:38 -0700
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Records Management Program <[log in to unmask]>
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Bruce White <[log in to unmask]>
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On Wed, Apr 14, 2010 at 9:46 AM, Malzone, Donna
<[log in to unmask]> wrote:
> Are there any guidelines as to the type of locking mechanism that should
> be used and who should have access to unlock the bins?  Also, should we
> stop allowing the vendor to open up the locked bins while at our
> facility?
Donna,

I work for a home healthcare company.  Like you we maintain PHI
material and use a third party vendor for our shredding.  We decided
against recycling and require all of our documents to be shredded -
less decision making by our employees.  We've determine that the
additional risks of inadvertently releasing PHI and other personal
information outweigh the extra costs for shredding.

I'd suggest before you make any decisions regarding the locks I would
review your contract with your vendor and see what their
responsibilities are.  In our case the vendor owns the bins and is
responsible for securing them.

Bruce White, CRM, PMP
Orange County, CA
e-mail: [log in to unmask]

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