Covid-19 is understandably impacting on our working day, including the way we manage and handle records as discussed in our previous blog on coronavirus precautions when handling records.
We’ve had a number of queries about COVID and records management recently, so here is the second query of the month for April.
It’s based on a couple of queries we’d received from hospitals about a strategy they had implemented to deal with records contaminated by COVID-19.
- Ensure that records created or amended in a secure (and contaminated) area are not removed from the area.
- Contaminated records should be digitised by a staff member wearing all the correct PPE, while still in this secure area, and uploaded to the required system/file location/shared drive as required.
- Once scanned, a quality assurance check is done to make sure the digitised version is a complete and accurate copy and fit for purpose.
- Outside of the secure area, the digitised versions are:
- either printed and attached to the (clean) physical file OR
- captured in the relevant eDRMS or application as per their usual practice.
They wanted to know:
- if they could dispose of the contaminated hardcopy records or if they had to keep them
- what to do with the digitised version if they were printing it and keeping the printed version as the master record.
Answer part 1: Digitising and disposing of the contaminated original
Of course, the health and safety requirements should always come first.
The disposal of source records guideline and physical source records disposal authorisation allow for the disposal of the contaminated hardcopy records once they’d been digitised and quality assurance checks had been done.
This does apply to temporary records only though, so if you have permanent value records that have been contaminated, get in touch with us to determine your next steps.
Overall, the primary objective is to make sure that there are complete and reliable records relating to the business activities being undertaken, regardless of the format.
Answer part 2: Printing a physical copy of the digitised record
You can print a copy of the digitised record to keep a physical copy, but whether you can dispose of the digitised version depends on which is the ‘master’ record and which is the ‘copy’.
If you need to keep a physical version as the master record, and the digitised version is just a ‘copy’, here’s what you could do.
Option 1 – Keep the digitised and printed version
If you keep the physical printed version and the digitised one, they will both have to be managed as public records and retained for the full retention period.
You’ll also have to consider is how you control the 2 versions so that your master is always a complete and accurate record.
Option 2 – Just keep the printed version
If you are only keeping the physical printed version as your master, and don’t need the digitised version, then you need a disposal authorisation to be able to destroy the digitised version.
Both the physical source records disposal authorisation and the digital source records disposal authorisation are out as they cover physical to digital (or other format) and digital to digital migrations respectively, not digital to physical format changes.
- nothing has been added, annotated, changed or deleted
- the copies have been created, distributed, and used only for reference purposes.
One of the examples listed here is ‘an unaltered electronic copy where the paper version is the official record’.
So, as long as the digital version is exactly the same as what you first scanned and then print for filing, the digitised copy can be destroyed.
Just make sure that it is a true copy, it doesn’t fall under any of the exclusions, and you’ve met any other requirements you may need to meet first.
In case you weren’t aware (you probably are), Queensland Health has some resources for the records, information and data managers.
The following 2 documents both contain some general recordkeeping advice on the management, retention and disposal of records that may have been affected by the Coronavirus (COVID-19).
- Coronavirus (COVID-19) data and application custodianship Policy
- Coronavirus (COVID-19) data and application custodianship Guideline
As usual, if you have any questions please email us at email@example.com.