Destruction and Recycling

Destruction/disposal of Product/Material or Media

Purpose
The purpose of this policy and procedure is to assure that Product/Material or Media is destroyed in accordance with standard destruction policies.

Policy
It is the policy of IFS to ensure the privacy and security of Product/Material or Media in the maintenance, retention, and eventual destruction/disposal of such media. Destruction/disposal of Product/Material or Media will be carried out in accordance with federal and state law, state policy and as defined in IFS’s retention policy. The schedule for destruction/disposal shall be suspended for records involved in any open investigation, audit, or litigation.

Procedures
All destruction/disposal of Product/Material or Media will be done in accordance with federal and state law, state policy and following IFS’s written retention policy/schedule. Records that have satisfied the period of retention will be destroyed/disposed of in an appropriate manner.
The Destruction/disposal department is meticulously maintained to ensure top quality service and is staffed with two supervisors and a dedicated full-time crew. Extra attention and detail is adhered to based upon our client’s specific needs. IFS can provide detailed digital imaging to ensure client satisfaction and piece of mind knowing their product is being securely destroyed/disposed of each and everytime
Records involved in any open investigation, audit or litigation should not be destroyed/disposed of. If notification is received that any of the above situations have occurred or there is the potential for such, the record retention schedule shall be suspended for these records until such time as the situation has been resolved. If the records have been requested in the course of a judicial or administrative hearing, a qualified protective order will be obtained to ensure that the records are returned to the organization or properly destroyed/disposed of by the requesting party.
Records or other documents containing Product/Material or Media scheduled for destruction/disposal should be secured against unauthorized or inappropriate access until the destruction/disposal of consumer information is complete. This means that this material should be stored in secure containers (not in wastebaskets, boxes, recycle bins, etc.) until the time of destruction/disposal.
Contracts between IFS and its business associates will provide that, upon termination of the contract, the business associate will return or destroy/dispose of all consumer health information. The destruction of Product/Material or Media by the Business Associate will be documented in writing and sent to IFS.

Date of destruction/disposal.
Method of destruction/disposal.
Description of the destroyed/disposed record series or medium.
Inclusive dates covered.
A statement that the consumer information records were destroyed/disposed of in the normal course of business.
The signatures of the individuals supervising and witnessing the destruction/disposal.
If such return or destruction/disposal is not feasible, the contract will limit the use and disclosure of the information to the purposes that prevent its return or destruction/disposal.

A record of all case files containing protected health information that are destroyed or disposed will be made and retained permanently by IFS. Permanent retention is required because the records of destruction/disposal may become necessary to demonstrate that the consumer information records were destroyed/disposed of in the regular course of business. Records of destruction/disposal should include:
Date of destruction/disposal.
Method of destruction/disposal.
Description of the destroyed/disposed record series or medium.
Inclusive dates covered.
A statement that the consumer information records were destroyed/disposed of in the normal course of business.
The signatures of the individuals supervising and witnessing the destruction/disposal.
If destruction/disposal services are contracted or performed by another state agency, the contract or agreement will provide that IFS’s business associate will establish the permitted and required uses and disclosures of information by the business associate as set forth in the federal and state law and include the following elements:
Specify the method of destruction/disposal.
Specify the time that will elapse between acquisition and destruction/disposal of data/media.
Establish safeguards against breaches in confidentiality.
Indemnify IFS from loss due to unauthorized disclosure.
Require that a non-state government business associate maintain liability insurance in specified amounts at all times the contract is in effect.
Provide proof of destruction/disposal.

Consumer information media will be destroyed/disposed of using a method that ensures the consumer information cannot be recovered or reconstructed.

Methods of destruction/disposal may be reassessed annually by the Security Officer, based on current technology, accepted practices, and availability of timely and cost-effective destruction/disposal services.