Client Document Retention - NNEDV
The Confidentiality Institute
Protecting Privacy, Securing Safety
Julie Kunce Field, J.D.
julie@
CCADV PRIVACY AND CONFIDENTIALITY PROJECT
Sample Client Document Retention Policy/Procedures(
Policies
✓ No record of client involvement with [Agency Name] shall be retained beyond [recommended: one year or less] after the client’s disengagement in services under the terms set out below.
✓ The destruction of all client records must be completed at a [Agency Name] facility by [Agency Name] employee.
✓ Non-personally identifying, aggregate information regarding services provided to clients, and non-personally identifying demographic data will be kept for not more than [ recommended: seven years or less], as may be required by any specific funder. Such non-personally identifying, aggregate data will not be maintained in any way that could inadvertently identify any individual client.
Procedures
Emergency shelter and transitional housing clients:
✓ Upon exiting the Safehouse or transitional housing program, [Agency Name] staff will retain the client’s intake form, exit form, and signed Releases of Information.
✓ Retained documents will be stored in a locked file cabinet in the Safehouse.
✓ [Recommended: Three months or less] after the client’s exit, all documents listed above will be shredded by a [Agency Name] employee.
Outreach and legal advocacy clients:
✓ During a client’s participation in [Agency Name] outreach and legal advocacy programming, [Agency Name] staff will retain the client’s intake cover sheet, any signed Releases of Information, and case notes dating no more than [Recommended: three months or less] prior.
✓ Documents will be stored in a locked file cabinet in the Safehouse.
✓ [Recommended: Three months or less] from the date of the client’s last involvement with [Agency Name] programs, all documents listed above will be shredded by a [Agency Name] staff member.
Client Master List:
✓ [Agency Name] will maintain a master list of all clients who have resided in the Safehouse for the previous twelve months.
✓ Each month, during the first week of that month, a [Agency Name] staff member will edit the list and delete all information for clients who exited the shelter more than [Recommended: twelve months or less] prior.
Perpetrator Master List:
✓ A list of the abusers of [Agency Name] clients will be maintained permanently by the shelter director. Such list will not reference any individual client/victim of such perpetrator.
Funder-required information:
✓ Non-personally identifying, aggregate information regarding services provided to clients, and non-personally identifying demographic data will be maintained by the shelter director.
( Thanks to Vicki Lutz, Esq. of Crossroads Safehouse, Fort Collins, CO who developed the original version of this form.
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