A restricted subject may need to be reviewed for an assessment while remaining under legal hold. The Data Custodian keeps the handling purpose and retention context visible, decides access within the customer's policy and records the authority for any disclosure. Agree those policies before introducing live information.
Data Custodian records the subject code, identity reference and access purpose. Set the retention date and legal-hold flag from the customer's approved handling instructions. A date that has arrived prompts review of the record and its hold.
Data Custodian approves an access grant for the named team member, stated purpose and expiry. Record the approver and check that the recipient is the intended person. Configure the agreed access restrictions before the grant is used in operational work.
Data Custodian checks the separate disclosure authority and records the actual recipient, scope, time and authority reference. Match the disclosure to the correct subject. An internal access grant does not by itself authorize information to be shared with a recipient.
Data Custodian reviews expired access and subjects whose retention date has arrived. Preserve any legal hold while the handling decision is examined. Admin supports permission checks; the custodian retains responsibility for the purpose and authority recorded.
And how to keep it from happening.
Start free, then use Proto to change fields, steps and approvals before your team goes live.