Part III: What to Shred and Throw Away
So far in the series we’ve discussed what documents are permanent and what records are beneficial to scan. So what about when it is time to get rid of paper? Do you know what is safe to throw away and what needs to be shredded? Chances are a considerable amount of paper you dispose of contains protected information. Whether it is a federal regulation like HIPAA or Sarbanes-Oxley or avoiding identity theft liability, your organization has a responsibility to securely dispose any record with personally identifying information.
The Health Insurance Portability and Accountability Act of 1996 protects an incredible amount of information, but specifically requires that the following information about a patient, their family or household member or their employer be secured:
- (A) Names;
- (B) All geographic subdivisions smaller than a State, including street address, city, county, precinct, zip code, and their equivalent geocodes, except for the initial three digits of a zip code if, according to the current publicly available data from the Bureau of the Census:
- (1) The geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and
- (2) The initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000.
- (C) All elements of dates (except year) for dates directly related to an individual, including birth date, admission date, discharge date, date of death; and all ages over 89 and all elements of dates (including year) indicative of such age, except that such ages and elements may be aggregated into a single category of age 90 or older;
- (D) Telephone numbers;
- (E) Fax numbers;
- (F) Electronic mail addresses;
- (G) Social security numbers;
- (H) Medical record numbers;
- (I) Health plan beneficiary numbers;
- (J) Account numbers;
- (K) Certificate/license numbers;
- (L) Vehicle identifiers and serial numbers, including license plate numbers;
- (M) Device identifiers and serial numbers;
- (N) Web Universal Resource Locators (URLs);
- (O) Internet Protocol (IP) address numbers;
- (P) Biometric identifiers, including finger and voice prints;
- (Q) Full face photographic images and any comparable images; and
- (R) Any other unique identifying number, characteristic, or code, except as permitted by paragraph (c) of this section;
If this list is not daunting enough this does not even run the gamut for information protection regulations. Regulations span every industry: in accounting, technology, legal, medical or retail, there are consequences for information breaches. In view of this list alone, there is too much risk in not securing your records destruction procedures.
Our policy at ASI is that all paper not being retained is to be shredded regardless of what information it contains. We strongly believe this is the best way to truly ensure that personal information is protected. All of our employees are trained to abide by this policy. This method is prescribed by the National Association for Information Destruction (NAID). NAID lists destruction policies, training, and paper record destruction in the top ten data protection compliance recommendations. For more information on how to keep your organization compliant, we are able to provide our clients with the Information Destruction Policy Compliance Toolkit compiled by NAID. Watch this preview, or click here to request your own Toolkit.