I interpreted this similarly, Pilar.  Thanks for the guidance and
confirmation!


Jeanine L. Baron
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-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Pilar McAdam
Sent: Friday, September 14, 2012 2:23 PM
To: [log in to unmask]
Subject: Re: Documenting Disposition Errors

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
[log in to unmask]
Los Angeles, CA







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