ICE Chips

Q: Our company policy has always included the phrase “No cameras allowed” in our plant. With the advances in today’s technology, is this good enough?

A: This is an interesting topic. Dr. Cliff Pappas, Head of Quality Systems at AIB International, recently discussed this issue with an attorney. The results of the discussion were thought provoking.

Advances in technology have redefined the scope of what a photograph represents. In the past, we were concerned with photographs being used as evidence or for other purposes. When copy machines were introduced, we were concerned that they were being used to reproduce documents. Since this technology was initially thought to be similar to a camera, we relied on camera policies to include document reproduction.

The digital age has expanded the methods available for replication. We now have digital cameras, camera phones, scanners, and the ability to electronically duplicate and transfer documentation. It could be argued that the phrases used in our policies (i.e. “No cameras allowed”) may no longer be adequate to prohibit this from happening.

To effectively protect against every possible means of information collecting and duplication of potentially sensitive information, a broader statement is necessary. For example, your policy could state: It is not permissible to memorialize, except in written format, or without prior written approval or specific legal mandate, any observations or findings from this audit.

The language in this statement clearly limits how a report can be documented to the written form only. Prior written approval and/or a legal mandate are the only exceptions. An example of this would be the courts’ decision to allow OSHA personnel to use photographs as a means of documenting offenses.  AIB