Erin--
I believe that's correct; only authorized individuals may access personal
information defined in FERPA and HIPAA. In any case, that shouldn't
prevent the Records Mgmt Dept from managing the content, the scanned
images in this case. Accessing the data and managing it are two different
things and each must be handled appropriately. Cannot be a
one-size-fits-all approach.
Stephen Cohen
MetLife
New York NY
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