WHEN , NOT IF : The Holistic Approach to Risk Mitigation CONTINUED FROM PAGE 38
will be much more limited , and you will know how to dig in and move forward .
HOW TO EXECUTE A HOLISTIC APPROACH Step One : Before Any Incident When it comes to incident response , proactive is far better than reactive . The investment you make in preparing for an eventual incident well before it occurs should include a careful evaluation of your business ' s hiring , onboarding , orientation , training , retention and document management processes . To help with brainstorming related to these evaluations , see the resource on page 42 .
To get a sense of any potential holes that may exist in your processes ( and , just as importantly , documentation of them ), pick up a few employee files . What do you see ? Is there a record of recent training ? Are there any notes related to performance ( good or bad )? Is paperwork up to date ? If someone asked for a particular employee ’ s file for a lawsuit tomorrow , would you be able to support your contention they are a great employee , they are qualified , they are sufficiently trained and have no complaints against them ? What does the paper prove ? If it is lacking , find some time and help to get your files in order . Update your spa policies and protocols . Not only does this protect you , but refreshers in training your employees can remind them of techniques they may have brushed aside , excite them about their trade and improve the customer experience .
When training is complete , make a record of it ( i . e ., have the employees sign a sheet that identifies the training and includes a brief summary of what it covered .
Make copies for each of the employees ’ files , or keep a training folder for all such events to take place on a quarterly basis ). Now , you have just enhanced your inhouse protection and your customer experience in the same 30 minutes . If you bring donuts and allow for a 90s rap music dance party in the last five minutes , you have also likely increased your employee retention .
If it isn ’ t already clear , let me reiterate : Document management is crucial . Know what you need in your files , and make sure it is there for however long it is supposed to be there . You should also know the legal term “ discovery .” In litigation , discovery entitles opposing attorneys to any non-privileged documents , materials or information related to claims , defenses , employees and operations . Discovery is extremely broad , so be prepared — anything you have could be turned over to an adverse attorney . This includes emails . Be careful what you write and who is copied . Even deleted emails can be recovered , so it ’ s best to save them so your attorney will know what they are dealing with . Most importantly , don ’ t ever remove or destroy something that should be saved , particularly if corporate or a lawyer has issued a “ litigation hold .” Spoliation is real and has real legal consequences .
Step Two : Incident Response Your spa ’ s incident response is only as good as its plan . If your employees have been trained and have bought into the goal of running a cohesive spa and wellness center , that plan should be strong . Each employee should understand how they fit into the puzzle . For instance , if there is a slip and fall near the steam room , how do you find out about it ? Is a
40 PULSE • MAY / JUNE 2022