Managing Chain of Custody for Off-site Records

The question of being able to ensure that you can maintain the chain of custody is something that has come up a lot lately in conversations I have been having.  It is clear that everyone is more cautious in today's highly regulated business environment, and so being able to prove who handled records and when is important. That proof allows you to demonstrate a complete chain of custody as records move your off-site storage facility.

All these discussions reminded me of a short article I write some years ago, which clearly still has relevance today... 

Records or data are considered to be in your custody when they are:

• In your physical possession
• In your view, after being in your physical possession
• In your physical possession and then locked up so that theft or tampering cannot occur
• Kept in a secured area, with access restricted to authorized personnel only.

Therefore, whenever a record is touched, you need to have proof of that activity, and you need to prove where it was stored. This may seem obvious, but what may not be so clear is that by creating an audit trail you provide two essential functions and, as such, you need a database capable of recording and handling the volumes of activity generated. So what are those functions and how do they benefit the client and you?

Firstly, and most important to the client, they are purchasing peace of mind when they store their records with you. They want to sleep at night knowing their records are safe and secure and you have to be able to prove that, when called upon to do so. There are many activities in a records management business, but some clearly need you to be able to provide date & time stamps of when those activities took place. Some of the most obvious ones are:

• Date & Time of pickup (and who picked them up)
• Date & Time of receipt at your facility (and who received them)
• Date & Time of being placed into permanent storage (and who placed them there)
• Date & Time of a request to retrieve records (and who took the request and who was the requestor)
• Date & Time of retrieval from the permanent storage location (and who retrieved the record)
• Date & Time of delivery (and who delivered the record, and who signed for the record)

These are obvious because they are very similar to what you expect from FedEx^® or UPS^®. You need to ensure that you have the proper tools, such as O'Neil Software's RSMobile^® software, and the very best database for recording all this activity. Most people miss an important fact with their activity/audit records when thinking about databases. In the example of obvious audit time stamps above, one new record created six audit records. This means, in this simple example, your database has to be capable of scaling to encompass activity more than six times the size of the number of records stored. That’s why scalability and selecting the right software, such as O'Neil Software's RS-SQL^®, is essential, so that you can maintain all this activity/audit history and can call upon it in a moments notice to satisfy a customers' request for proof of chain of custody.

The second and most important point of all this activity is that it accurately records what actually took place. This data is very important for billing and reporting purposes. With accurate activity/audit data, your records management system will be able to quickly create invoices for your clients. Each activity will have a charge associated with it and one of the key factors of a successful records management business is to ensure you charge for everything that has a cost associated with it. Not only can you have detailed, accurate invoices, but you can positively prove every charge was justified, should the need arise. These data records provide you with your peace of mind that the business is collecting all the charges due and your customers have confidence in their invoices. It is not uncommon to hear of more than 10% increases in service revenue, when the O'Neils Software's RS-SQL^® records management software is used, simply due to the ability to record activity automatically and accurately.

So who knew that by providing an accurate chain of custody, you can afford both your client and yourself peace of mind? Sleep well.