• Employers must keep drug and alcohol testing records in a secure location with controlled access.

Employers must maintain records associated with Department of Transportation (DOT) alcohol and drug programs. The information appearing on the documents contains personal identifiable information, drug or alcohol test results, and rehabilitative information in the event of a DOT testing violation.

The sensitive nature of these documents requires confidentiality. The DOT rules in 382.401 require that records be kept in a secure location with controlled access.

For hard copies, a secure location means a locked file cabinet or office. Documents that are stored electronically should be password protected. For larger organizations with corporate drives, only those who have a need to see the DOT drug and alcohol testing records should be granted access through the company information technology (IT) department.

Who should have access?

A company must decide who needs access to all or some DOT testing program records. It goes without saying that anyone acting as administrator of the program will need access to the files. Employers then need to decide which supervisors and human resources (HR) professionals may need access, and whether workers in these roles need access to all or portions of the information.

Another consideration is a company’s support staff. Are there, for instance, administrative assistants who have been tasked with filing or uploading documents? These individuals will need access to carry out essential job functions, but like any other employee with such access, employees in these roles must understand the potentially sensitive nature of these records and the importance of keeping related information confidential.