Your company needs to include you in the process of managing t
Jeanne,

Your company needs to include you in the process of managing these records -- however, these records belong to the clients. The format of the records is irrelevant, but you will need to have direction from your clients on both what to do with the imaged paper as well as what to do with the images. My guess is that the folks managing these services likely have not done much in terms of addressing these issues with clients and have either agreed to terms proposed by the clients or left the contracts silent on records retention beyond "records will be maintained".

Having been on both sides of outsourcing or record-keeping (and not simple records center storage), the management of client records when your firm is also the processor of the records is a complex undertaking unless clear parameters have been established.

There may well be certain records created during the processing that belong to your company (i.e. call center records, service tickets, etc.), but these should be clearly delineated in the contract for services. My prior employer felt that call center recordings belonged to the service provider, but not all clients saw it that way.We also regularly had clients attempt to impose their records retention requirements on our corporate records (such as time records for staff assigned to that client).

You will need to work closely with your legal team and the client services operations staff to understand the terms and conditions of the work, as well as the processes that are involved with client records. It is important that good records management practices are followed and that your company is protected, as well as the client.

Also, given the sensitive nature of the types of records that you described, close attention should be paid to data privacy and information protection considerations. You'd hate to find out that someone is dumping paper drug testing records in the trash after imaging.

In general, client records should not be governed by the "corporate" retention schedule. That said, you should have some governing document that describes (generally) how client records will be maintained. This is always subject to contractual agreement with your clients. If anything, you can add a line item called "client records" to your corporate retention schedule and point to client agreements as the governing retention period. These are not your company's records. What you do want to be certain of is that you have a means to return the records to your clients or dispose of them at some point after the client engagement is over -- again, this should be dealt with in the client engagement agreement.

 
Patrick Cunningham, CRM, FAI
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