This Records Retention and Privacy Policy describes how we collect, use, retain, protect, and dispose of information obtained or created while performing industrial hygiene, environmental, hazardous materials, and related consulting services ("Assessments"). Our practices reflect our contractual obligations, applicable regulations, and customary industry standards.
Information We Collect and Maintain
During the course of an Assessment, we may receive, generate, or retain:
Facility descriptions, maps, drawings, and layout information
Environmental data, inspection reports, and regulatory correspondence
Industrial hygiene surveys, sampling data, and exposure evaluations
Engineering studies, audits, and risk assessments
Safety and health program materials
Work Orders, Purchase Orders, and written instructions (including email, fax, and electronic signatures)
Billing records, reimbursable cost documentation, subcontractor invoices, and laboratory reports
Government records, chain-of-title documents, and permit-related materials
Notes or summaries of discussions with regulatory agencies or third parties
All such information is treated as confidential client property unless otherwise specified in writing.
Use of Information
We use client information solely for:
Conducting Assessments and preparing related reports
Providing professional advice, analysis, and recommendations
Supporting regulatory compliance and environmental management
Preparing invoices and supporting documentation
Meeting contractual and legal obligations
We do not use client information for marketing or any unrelated purpose.
Confidentiality and Trade Secrets
We may receive technical data or other information that the client designates in writing as confidential or a trade secret. We will use reasonable efforts to prevent disclosure of such information except as necessary to perform contracted services. We have no obligation of confidentiality for information that:
Was already known to us without restriction
Is or becomes publicly available through no fault of ours
Is obtained lawfully from a third party without confidentiality obligations
Is independently developed without use of client confidential information
We require subcontractors and independent contractors who receive client confidential information to follow the same confidentiality obligations.
Standard of Care and Professional Judgement
All advice, recommendations, findings, and conclusions are provided to the best of our knowledge, opinion, and belief, based on:
Information available at the time of review
Applicable laws and regulations
Market conditions, energy costs, wage rates, and other relevant factors
Changes in these factors may affect the applicability of prior conclusions. We may communicate information obtained from regulatory agencies or third parties. When such communications are undocumented, we are not responsible for discrepancies so long as we conveyed the information in good faith.
Ownership and Use of Work Product
Client Ownership
All reports, field notes, laboratory forms, written recommendations, and other work product prepared for the client become the property of the client upon delivery.
Industrial Hygienist’s Rights
We retain our general professional knowledge, skill, and experience, as well as copyright to training materials, applications, templates, and proprietary documents. These materials may be used by the client only for internal purposes and may not be resold or redistributed.
No Long-Term Storage of Originals
We do not maintain original records, data, or writings after they are delivered to the client. The client is responsible for maintaining records as required by law.
Finality of Reports and Prohibition on Modification
Our reports, findings, recommendations, and conclusions are professional work products prepared using the best information available at the time of assessment and in accordance with customary industry standards. These documents represent our final professional judgment. Clients may not:
Edit, revise, or alter any portion of our reports
Remove context, disclaimers, or qualifying statements
Modify conclusions or data to reflect preferred outcomes
Reinterpret findings for purposes outside the original scope
Use our work product in advertising, marketing, or promotional materials without written authorization
If conditions change after the date of assessment, or if new information becomes available, we may perform additional work under a new Work Order. Previously issued reports remain final and unchanged. Unauthorized modification, reinterpretation, or redistribution of our work product is strictly prohibited.
Records Retention
Delivery of Original Records
We provide clients with all original records and documents as soon as possible after completing our work. These originals constitute the official project record and are the only authoritative copies.
Client Responsibility for Long-Term Retention
Clients are responsible for maintaining their records in accordance with applicable Health and Safety, Environmental, and Industrial Hygiene requirements, which may extend up to thirty (30) years. We strive to provide low-acid, archive-quality documents suitable for long-term retention. Field notes are inherently sensitive to age and should be stored with care.
Electronic Copies
We maintain electronic copies of records for up to two (2) months after all accounts related to the project have been settled.
We may retain records longer at our discretion, but accuracy or availability of stale records is not guaranteed.
Requests for electronic copies must be made within the two-month window.
When appropriate, we can provide secure electronic copies, typically in sealed Adobe Acrobat PDF format.
Billing and Reimbursable Cost Records
We maintain accurate records of reimbursable costs. These records are open to client inspection and audit during the contract term and for three (3) years after termination.
Termination
Upon termination of a contract:
We will deliver all originals and copies of data to the client
We retain only one copy as permitted under Section 8 (if applicable)
All other copies are returned or destroyed
Regulatory Requirements
If a project involves regulated materials (e.g., asbestos, lead, hazardous waste, occupational exposure data), we follow the retention requirements of applicable federal, state, and local regulations.
Records Destruction
At the end of the applicable retention period, records are securely destroyed unless:
The client requests return of the records
A legal hold or regulatory requirement mandates continued retention
The client requests earlier destruction and no legal obligations prevent it
Destruction methods include secure digital deletion or physical shredding.
Data Security
We maintain reasonable administrative, technical, and physical safeguards to protect client information, including:
Controlled access to project files
Secure storage of electronic and physical records
Protection of sensitive environmental and facility data
Limiting access to authorized personnel only
We take appropriate measures to prevent unauthorized access, disclosure, alteration, or loss of client information.
Subcontractors and Independent Contractors
We may use subcontractors or independent contractors to perform portions of the work. When doing so:
They must maintain appropriate insurance
They must follow the same confidentiality and liability limitations
We remain fully responsible for their work
We ensure no liens are placed on client facilities
Subcontractors may not use or disclose client information except as required to perform their assigned tasks.
Site-Specific Provisions
When working on client facilities:
We follow all client-provided safety rules and regulations
We take reasonable precautions to minimize damage
The client is responsible for costs of any alterations or damage required to perform the Assessment
Restoration work is performed only upon written request and at the client’s expense
Electronic Communications
We accept written instructions via email, fax, electronically signed documents (PDF or similar), and other electronic submissions. Electronic signatures carry the same weight as original signatures.
Jurisdiction
This policy and all related services are governed by the laws of the State of California. Any disputes arising from contracted services fall under the jurisdiction of Manhattan Beach, California.
Updates to This Policy
We may update this policy to reflect changes in legal requirements, industry practices, or our service offerings. The most current version will always be available on our website. We respect the privacy of our clients, partners, and website visitors. In our role, we often work with sensitive project information, and we are committed to protecting the confidentiality and integrity of all personal and business data we handle.
Why Clients Choose DNA
CIH‑Led Expertise - All major projects are overseen by Certified Industrial Hygienists with decades of field experience. Clear, Defensible Reporting - Our documentation is structured for regulatory review, legal defense, and practical decision‑making. Responsive Field Support - We mobilize quickly for urgent needs, including IAQ complaints, water intrusion, asbestos/lead disturbances, and environmental releases. Comprehensive Capabilities - Industrial hygiene, environmental assessment, remediation oversight, and training — all under one roof.
