James,

I think it is a good idea to document that a third party is destroying records you consider to be yours, because your organization is still responsible for them. There are two avenues you can use: The first is your organization's third party management system. If it is robust enough to include records management, then by all means include destruction documentation in your assessment.  In the case of you third party management system not being that comprehensive, you can try the tack of working with your legal department to have appropriate language put in contracts wherein the third party is managing records you consider to be yours.

Gary 



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