8VAC20-781-50 General recordkeeping

C. The licensee shall keep all records required by 8VAC20-781-60 and 8VAC20-781-70 in locked files or a secure electronic file, except for those required to be accessible pursuant to 8VAC20-781-600; and access to such files should be restricted according to a principle of least privilege.

• Children’s names, birthdate, parent names, designated pick-up persons, allergy information, health information all need to be readily available to staff caring for children.
• VAC20-781-30 C. Requires the center to “maintain a written list, for each group of children, of important health conditions and dietary restrictions. The list shall only be accessible to staff and shall be in each room or area where children are present and kept confidential...”  These areas will include field trips and playgrounds where locked files are unavailable. 
• This information is required to be confidential. Remove the requirement that it be locked or secured.