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To amplify it just a bit further... From the 2257 Client Handbook authored by two leading attorneys, Paul J. Cambria and Roger W. Wilcox...
from page 30 of the above mentioned document...
2.2.5.1 What Cannot Be Kept In 2257 Records?
Producers should first note that 28 C.F.R. 75.2(e) warns that ?[r]ecords required to be maintained under this part shall be segregated from all other records, shall not contain any other records, and shall not be contained within any other records.?
The rules obviously anticipate a discrete, contiguous record keeping program that will not require authorized law enforcement agents to hunt through a convoluted filing system. Violation of the records segregation requirement exposes producers to criminal sanctions.
Consequently, it is important to ensure that extraneous documents such as model releases, medical records, and personal information not required by 2257 be excluded from 2257 records.
Indeed, given that many states have laws protecting confidential information such as HIV status, there are reasons beyond the 2257 rules that augur in favor of carefully vetting the materials placed in 2257 records.
... and from page 32-33 of the same document...
An analogous system can be created and maintained in a digital environment, and probably more easily. However, if you do choose the digital process, keep the records on a stand-alone PC that is not connected to your network, and which does not contain any information other than that required for 2257 compliance.
This will meet the segregation requirement of 28 C.F.R. 75.2(e), and will also ensure that inspection of your records and/or seizure of your 2257 records does not interfere with your business operations.
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2257-Ben
www.2257ware.com
The BEST, most compliant 2257 record-keeping software available. Period.
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