At workplaces that run alcohol checks, test results are kept for each individual. These records can include information that links to specific employees, such as who was tested, when, the result, and whether a retest was done. When an audit is scheduled, the safety and health, HR, and general affairs teams often try to gather all of these records and submit them, but copying and sharing every individual original widely is not always necessary just because it is for an audit.
Here, an individual original means the first record that holds each person's test result, test time, handling history, and so on, entry by entry. Audit materials, by contrast, are prepared for submission to explain whether the check program was run according to the set standards. The key is not to attach every original, but to answer the audit's questions with aggregates and operating documents, and to make only the specific entries needed available for review in a controlled way.
Split the scope of materials by audit question first
What an audit wants to confirm usually falls into three areas. It asks whether check standards were in place, whether checks were done for the designated people at the designated times, or how specific incomplete or disputed cases were handled. These questions require different levels of material, so there is no reason to put all individual originals in the same folder from the start.
To explain the program itself, you can present the approved check standards, how the people to be tested are selected, the roles of those in charge, and any changed standards with their effective dates. Whether the program was run centers on figures by period: the number of people scheduled, the number completed, and the number of incomplete checks broken down by reason. It is appropriate to link individual records separately only when the handling of a specific case must be confirmed, and only for the period and people requested.
If the audit request does not make clear the purpose, period, people covered, and recipient, it is best to settle that scope first. For example, a request to confirm "operating status" and a request to confirm "how a specific dispute was handled" do not call for the same materials. The basis and authority for the request also need to be checked separately, and an internal audit does not automatically mean unlimited access.
Aggregate tables must explain what the numbers mean
If you submit aggregate tables instead of individual originals, you need to explain what the numbers mean. If you present only a completion rate, it is hard to see how people who were scheduled but not tested, cancelled schedules, and retests were counted. If the number of people and the number of test attempts are combined into one figure, the operating status on days with many repeat tests can be misread.
It is useful to state in the aggregate material the period and site covered, how the scheduled headcount was determined, and how completed, incomplete, cancelled, and retest cases were calculated. For periods with no data, distinguish whether no tests were done or the data was not collected. If a range whose originals have not been confirmed is simply shown as "0 cases," the audit may reach a conclusion that differs from what actually happened.
| What the audit looks at | Materials to prepare first | When individual originals are needed |
|---|---|---|
| Whether a check program exists | Check standards, revision history, roles of those in charge | When separately confirming that a specific standard was actually applied |
| Whether it ran in each period | Scheduled, completed, and incomplete counts with the counting basis | When checking part of the aggregate figures against a sample or specific entries |
| How a specific case was handled | The action flow and handling times for that case | When reviewing the original records for the requested people and period |
The aggregates in the table do not mean the originals should be discarded. They are a way to let the auditor understand the meaning of the figures first, and to decide who may view which records when further confirmation is needed. Even if the submitted copy includes a link number for each entry, you need to manage separately whether that number alone makes an individual easy to identify and who holds access rights to the originals.
Structuring a submission in a hypothetical case
Take a hypothetical case. A manufacturing site is audited on how it ran its monthly alcohol checks, and the audit question is "were checks missed in any shift, and what was done after they were missed?" If the person in charge submits the full file of individual test results, the auditor will struggle to find what is needed and will also see the results of other employees unrelated to the question.
In this case, what to observe is the scheduled headcount for each shift, the number actually completed, the reasons for incomplete checks, when each incomplete check was identified, and whether follow-up action was recorded. Here, not every incomplete check means the same thing. You must separate people excluded from testing because their shift was cancelled from people who were due to be tested but were not, in order to interpret the scale of the missed checks.
As a possible action, you can first submit an aggregate table covering that month, site, and shift, the check standard document, and the handling flow for incomplete cases. If the auditor decides the facts of a specific incomplete case need checking, only the original record for that case is then reviewed through the access route. The completion criterion is not a state in which all originals have been handed over, but one in which the figures and handling evidence for the audit question agree and any items needing further review can be pinpointed.
Keep submission copies separate from the stored originals
The most common problem when preparing audit materials is that the submission file spreads like a new original. If a file containing individual results is downloaded, edited, and then left in email, messengers, shared folders, and staff members' own PCs, it becomes hard to tell who saw which file. Even if parts are masked on screen, other people's information may remain in hidden columns, other sheets, file properties, or a downloadable original.
So you can consider marking the submission copy with its creation date, period covered, site, purpose, and version, and keeping it separate from where the originals are stored. If the content changes due to additional requests, keeping a new version that shows which items were added or removed, rather than overwriting the existing file, makes the history easier to explain. Before submitting, check the recipients and sharing permissions against the scope of the request, and after submitting, you also need a way to confirm who viewed the material.
Article 29 of Korea's Personal Information Protection Act requires personal information controllers to take the technical, managerial, and physical measures needed to ensure security, including establishing an internal management plan and keeping access records. Keeping alcohol check originals separate from submission copies, and not leaving temporary access rights for audit purposes open indefinitely, can be ways to put these safeguards into practice.
After the audit, track where the copies went
The end of an audit does not mean the original records can be deleted right away. Check records may continue to be kept according to the workplace's retention standards and the purpose of the records, and tidying up submission copies must be decided separately from retaining the official original records. Conversely, if temporary shared folders and files sent outside remain after the audit ends, the possibility of access beyond the original audit scope continues.
It is better to decide from the start of preparation what will be done after the audit ends. For example, you can name the person who will close the temporary folder, the person who will revoke additional access rights, and the department responsible for the standard on keeping or deleting submission copies. This way, you can present traceable evidence for the questions the auditor raised without distributing every individual original widely.
In the end, the standard for alcohol management audit materials is not "did we include everything?" but "can we explain the operating evidence that fits the question, and can the necessary individual records be reviewed within a defined scope?" Building the basic answer from program documents and aggregate data, and linking the originals for specific cases only when the purpose and scope of the request are confirmed, is a starting point for managing both the audit response and the handling of personal information.
