How do you manage records access policy exceptions and deviations?

To identify an exception or deviation, begin by determining its type and scope. Assess whether it is a one-time or recurring request, and understand who is making the request and their purpose. Evaluate the involved records for sensitivity and potential risks. Consider the consequences of granting or denying access, including compliance with your records access policy and legal obligations. Document all details meticulously to ensure a thorough evaluation. By analyzing these factors, you can make informed decisions that balance operational needs with security and regulatory requirements, ensuring proper handling of exceptions or deviations.

Applying the principle of least privilege involves granting only the minimal level of access necessary for a specific task or purpose, and only for the shortest duration required. For instance, if a contractor needs to view a record for a project, provide access solely to that specific document, not the entire record series or collection. Additionally, restrict this access to the project's duration. By doing so, you minimize the risk of unauthorized access, misuse, or loss of records, ensuring that sensitive information remains protected and that access complies with security policies and legal obligations. This approach helps maintain control and security over sensitive data.

To implement controls and safeguards for records subject to exceptions or deviations, you should deploy several security measures: Encryption and Passwords: Use encryption to protect sensitive data and passwords to restrict access, ensuring only authorized individuals can view or modify records. Audit Logs: Maintain detailed audit logs to track and verify who accessed which records and when. This helps in monitoring usage and identifying potential security breaches. Backup and Recovery Plans: Establish robust backup and recovery plans to ensure records can be restored in case of damage or loss. Retention and Disposition Policies: Ensure records are returned or disposed of in accordance with your retention and disposition policies.

I would also recommend that a copy of the request, the receipt of the record, and any feedback or follow up requests be retained for future reference.

To communicate and document an exception or deviation, clearly inform all relevant parties, including the record owner, requester, approver, and records manager. Explain the rationale and conditions for granting or denying access, define roles and responsibilities, and outline expected outcomes and deliverables. Specify the access duration and expiration date, and establish procedures for reporting and resolving issues. Maintain a detailed record of the exception or deviation, including all communications and actions, for future reference and accountability. This ensures transparency, compliance, and proper management of the exception or deviation.

To review and evaluate an exception or deviation, assess its impact and effectiveness after completion or expiration. Verify that access was used appropriately and securely, and that records were returned or disposed of properly. Check for any incidents or breaches, and evaluate if objectives and expectations were met. Document any lessons learned and identify areas for improvement. Update your records access policy or procedures to incorporate changes or best practices identified during the review. This ensures continuous improvement, compliance, and enhanced security for future exceptions or deviations.