evening all
must be something in the air....
We have had a discussion today about the transfer of OH clinical records-I know I posted before but never had a reply.
By the term OH notes I mean OH clinical records - pre employment forms, health checks, FLT medicals, confined space medicals, OH referrals, OH notes, OH reports, emails, questionnaires/ graphs of spirometry, etc.
Not the "Health record" which is the certificate we issue to an employer following surveillance which has to be kept for 40 yrs.
Questions which raised today were.....
1- When transferring OH notes and the individual declines transfer of their notes, the previous OH provider has to keep the OH notes....anyone know how long??? how do you know when they leave???
2- what about old leavers notes - they wont have consented to transfer of notes. Do you charge a fee for keeping them? if so any idea if there is guidance on suitable fees?
3- I know the DPA says we should not keep unnecessary information. There is obviously different standards out there for example; one contract I had, the previous very large OH provider photocopied all the notes of the staff who consented to transfer (keeping the photocopy! I don't think they should not have done that as staff had consented to transfer of notes) and kept all the old and leavers files. Another one the previous provider sent me lock stock and barrel of all staff and anyone who had been employed at anytime....without any consent at all
4- I've also a key to a filing cabinet on the customer premises that has not been touched in years (without consent I assume) - what on earth do I do with them?? technically I dont have permission to read the notes! If I give up the contract (very tempting at present) what should I do with these as there will be no consent for onward transfer.
I know we have identified before that we need specific guidance where will this come from (hopefully the new organisation) and when it is a department where nurses come and go the old note management is loads easier than for small independent OH provider
In the interim (as I suspect it may be a while forthcoming) anyone (particularly independants) willing to share a notes transfer policy/protocol/procedure??? or direct me to where I can find answers as I don't want notes I don't need and I don't want to pass on notes without appropriate consent.
For those who have written policies- where did you find the guidance?
#there are more questions than answers#
Jacqui
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