Balance access with protection
A record that nobody can find is difficult to use as compliance evidence. A record available to everyone can create unnecessary exposure. AUSTRAC’s checklist recommends clear ownership, retrievable storage and controls for sensitive material. Design these together. Identify who needs a record for their work and how they obtain it. Avoid making an individual’s email account or phone the only location of important evidence. Security and retrieval should be planned features of the process, not competing fixes added after a problem.
Map the actual storage locations
Start with the places staff really use: customer systems, shared folders, approved messages, supplier portals and paper files. Identify the authoritative record and the links to supporting material. Suggested controls include role-based access, a named owner and a tested recovery process. Check what happens when a staff member leaves or a supplier account closes. A neat policy is not enough if the only working copy sits in a location the business cannot access without that person’s credentials.
- Record keeping checklist: Implement a system or process for record keeping; Secure sensitive records
- Working record
Identify the authoritative customer record.
- Supporting material
Keep usable links to documents, decisions and related transactions.
- Access test
Check retrieval when a staff member leaves or supplier access ends.
Can you recover the complete file?
Read this visual with the source conditions and explanation in this section.
Follow the process from top to bottom.
Example: the missing message thread
Imagine a customer instruction is recorded in an approved message channel, while the main file contains only a brief note. During review, staff cannot find the thread because it is tied to a former employee’s account. A practical improvement is a defined capture process that preserves the relevant message in the controlled record. This example does not recommend copying every conversation. It shows why the business needs a reliable method to retain the material that explains a customer instruction or decision.
Test access and recovery
Run a sample retrieval with an authorised user, then check that an unrelated user cannot access the same sensitive material. Verify that exported records remain readable and connected to the correct customer or transaction. Review permissions when roles change. Keep disposal controlled under the applicable retention rules rather than leaving copies across unmanaged locations. AUSTRAC also points to separate privacy responsibilities. Use those requirements when designing the wider record system; a successful AML retrieval test does not establish compliance with every security or privacy obligation.
Check exports before exit
Before closing a system or supplier account, verify that authorised staff can open the exported files and find the linked evidence. Preserve identifiers and relevant dates. A successful download is not enough if the business cannot interpret its contents. Document the retrieval result before removing the old access route.