Jeanine Baron asked about how to address the inadvertent (i.e., accidental, erroneous, outside-of-policy) destruction of files. My thoughts are:
1) It's happened to all of us.
2) When I come across this situation, I enter a note into our records system along the lines of, "Destroyed in error on 6/28/2009".
3) Whether to put something about this un-anticipatable (is that a word?) occurrence into your policies/procedures will depend on how formal your program is. If your procedures are very elaborate, then you probably should, but I'd keep it very brief. Maybe something like, "In the event that records are destroyed or made permanently inaccessible, regardless of the cause, before the completion of their required retention, a notation will be entered into the tracking system indicating what occurred and when."
4) If you have an internal audit program that includes corrective action plans, it should be able to encompass the identification of any systemic problems (rather than one employee's ignorance or vandalism) that need to be addressed.
Just one woman's opinion.
Pilar C. McAdam, CRM
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Los Angeles, CA
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