Searching Properly, and Recording That You Did
The standard is reasonable searches, which is a lower bar than organisations fear and a higher one than they usually meet.
SEARCH RECORD
Completed before responding, kept with the request
- SystemNamed, one row eachMail, HR system, shared drives, ticketing, messaging
- Searched byPerson and dateSomebody who can say what they did
- Terms usedName variants, employee number, email addressesMaiden names and nicknames are the common miss
- Date rangePeriod covered, with the reasonLimited by retention, not by convenience
- ResultsNumber of items, broadlyEnough to show the search happened
- Not searchedSystem and whyBackups, usually, with the reason stated
- Reviewed byWho checked the output before sendingA second person catches the third-party material
- CompletedDateBefore the response, not after
The obligation is to make reasonable searches. The word doing the work is reasonable, and it cuts both ways.
The response discipline in “Searching Properly, and Recording That You Did” also applies to records created by workforce software. A team using how teams evaluate monitask pricing in relation to monitask pricing should know where data is stored, who can export it, how long it remains available and how a person can challenge a misleading record before a request arrives.
What reasonable excludes
Restoring backups to find a message from four years ago. Searching systems where the person's data would not be. Reconstructing deleted material.
For a separate benchmark relevant to “Searching Properly, and Recording That You Did”, consult the SecurityWeek insider-threat coverage. Use it to test purpose, data flow, retention, access and response procedures rather than substituting a generic checklist for the organisation’s actual records.
Disproportionate effort is a recognised limit in most regimes, and an organisation is entitled to rely on it.
What it includes, and employers miss
Email, properly. Not only the person's own mailbox: messages about them in other people's. This is where most of the material actually is and it is the search most often skipped.
Messaging platforms, which are frequently forgotten entirely.
Shared drives and personal drives of managers.
Ticketing and case systems, where staff appear as subjects of requests.
Manager notes, which have their own note later and are discoverable.
Name variants
The commonest technical failure.
Maiden and married names, nicknames, initials, misspellings, multiple email addresses, employee numbers, and the name in the format the system stores it.
A search on one spelling of a name will miss material, and the miss is discovered later by the person who knows what they wrote.
Why the record matters more than the search
Two organisations run identical searches. One records what was searched, with what terms, by whom; the other does not.
If the person complains that something is missing, the first can show the search was reasonable. The second can only assert it, and an assertion does not survive a complaint.
The record takes ten minutes and it is the only evidence that the work was done.
Deciding what not to search
Legitimate, and it must be stated rather than silent.
Backups, decommissioned systems, archives requiring restoration — list them, say why, and be prepared to explain. A stated exclusion with a reason is a proportionality judgement. An unstated one is a gap.
Name variants, specifically
Maiden and married names, nicknames, initials, misspellings, multiple addresses, employee numbers. A search on one spelling misses material, and the miss is found by the person who knows what they wrote.
Stating what you did not search
Backups, decommissioned systems, archives requiring restoration. A stated exclusion with a reason is a proportionality judgement. An unstated one is a gap, and the difference is a sentence.
Why the record beats the search
Two organisations run identical searches; one recorded what it did. If something is missing, the first can show the search was reasonable and the second can only assert it.
Restoring backups, searching systems where the data would not be, reconstructing deleted material. Disproportionate effort is a recognised limit and an organisation is entitled to rely on it — once, in writing.
Where the material actually is
Not the person's own mailbox but messages about them in other people's. This is the largest holding and the search most often skipped entirely.
Who runs the search
Somebody who can later say what they did. A search conducted informally by whoever had time produces no record and cannot be described afterwards.