Even though it feels like it happened in a different lifetime, it wasn’t very long ago that people were going to the grocery store in hazmat suits, fighting over toilet paper, and spending most of their time at home.
Through all the weirdness that ensued during the pandemic, there were plenty of notable and lasting changes. Some companies adopted a permanent work-from-home model and many adapted to become more efficient in their processes. For records managers, the effects of the pandemic are (and will continue to be) seen in managing retention schedules.
During the pandemic, many companies collected vaccination information from their employees in an attempt to ensure a safe working environment. Now, the laws and changing records management regulations surrounding these records are changing. Access’ retention schedule software, Virgo™, informs privacy and retention policies by providing continuously updated legal research in 220+ jurisdictions around the world.
A pioneering regulation in Victoria, Australia is likely the beginning of more regulatory changes to come around the world surrounding pandemic-related records.
Records Management Regulations in Victoria, Australia
Employers operating in the state of Victoria, Australia must destroy all COVID-19 vaccination information recorded or held under the Occupational Health and Safety Amendment (COVID-19 Vaccination Information) Regulations 2022 by August 11, 2023. “Vaccination information” includes any information about whether someone has received any dose of a COVID-19 vaccination or if a person is unable to receive a dose because of a medical condition, medical illness, or age. These records management regulations do not specify how this information must be destroyed but industry best practices suggest the information be securely destroyed in a manner that avoids inadvertent disclosure.
Businesses must comply with this unless a law of Victoria or the Commonwealth or of any other state or territory either requires the information to be destroyed before this date or permits the information to be retained after this date.
While other Australian states/territories including New South Wales have not imposed the same record destruction deadline, they do insist that businesses choosing to retain information related to the COVID-19 vaccine ensure the information is securely stored, is not kept for longer than necessary, and is only used for the purpose for which it was collected.
Citation in Virgo as, “SR No. 53 of 2022 (Vic), Art. 21E”.
Beyond Storage – A Comprehensive Information Management Checklist
Organizations of all kinds and sizes are finding themselves faced with an array of information management challenges. Some of these challenges, like the transformation of information technologies and the growth of data sets, have remained relatively unchanged for years.
Keeping Up with a Pandemic-Related Retention Schedule
Employee vaccination information is just one type of record that records managers can expect new and changing regulations on. From case and contact tracing records to CARES Act documentation, companies must be aware of the retention requirements of all records generated during the pandemic.
If your organization hasn’t already updated its retention schedule to account for new record types created during the pandemic, this playbook can help guide you through the process and considerations: Playbook for Responding to Pandemic-Related Records: A Methodology for Analysis & Ingestion of New Record Types.
The Playbook presents a high-level plan for defining controls for the security, privacy, retention, and disposition of anticipated or existing pandemic-related record retention schedule and broader data concerns.Download a copy and ensure your organization is prepared for future regulatory changes related to these record types!
