At the university where I work we are in the process of reigning in and
putting some governance around a workflow and scanned image database that
quite a few departments have been using for awhile.  The same company that
makes this product also makes a records retention module that we will be
adding to the database to assist with applying the records retention
schedule to the images that are stored in it.

As the Records Management department proceeds we've found that we have the
need to access all the "drawers" where these images are stored to assist
with workflow development, best practices, and, of course implementing the
retention module.  Our IT department required that we ask permission of all
the image "owners" before giving us access.  Some of the image owners have
denied us access by saying that the images in the database contain
information covered by FERPA or HIPAA and, as such, we are not allowed to
see them.

Has anyone else out there encountered this?  Does FERPA or HIPAA really
exclude an internal department such as records management from viewing
records that are considered covered by these regulations?  

Thanks,
Erin Vandenberg
Director of Records Management
DePaul University
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