Record Integrity and Falsification Prevention Under ASC Indicator 1.3.2

Overview of Indicator 1.3.2 Requirements

Indicator 1.3.2 of the ASC Farm Standard Interpretation Manual establishes a core requirement:

The UoC shall ensure that information provided as evidence of conformance to the ASC Requirements is not falsified or misrepresented.

This requirement underpins the credibility of ASC certification. Records form the documentary foundation for both internal audits and external third-party assessments. The guidance in the Interpretation Manual identifies specific attributes records must possess and outlines corrective action procedures when falsification or misrepresentation occurs.

Record Documentation Standards

The ASC Interpretation Manual specifies that records must meet the following standards:

• Accuracy and preservation: Records must be completed and maintained in a way that ensures information is accurate and preserved over time.
• Genuineness: Records should be authentic and completed at the time of checks or shortly after the event they document. Records should not be backdated or created retroactively without clear notation of the timing.
• Capture of non-conformance: Records must capture and illustrate information when processes do not perform as expected. For example, if a cooling system fails and temperatures exceed acceptable internal limits, those temperatures must be recorded so management can identify systemic gaps. Recording only temperatures within acceptable ranges prevents management from recognising the need for backup systems or corrective action.
• Legibility: Records must be readable and clear so that information can be understood by auditors, management, and relevant staff.
• Completeness: Records should be complete and may include a form of authorisation through supervisor initials or signatures verifying that all required information has been captured.
• Appropriate storage: Paper records must be stored in ways that prevent damage, deterioration, or loss. Electronic records must be backed up to ensure data is not lost due to system failure.

Compliance Checklist for Record Management

Documentation Practices

1. Establish a records management protocol specifying who is responsible for completing each type of record (e.g., daily water quality logs, treatment registers, mortality records).
2. Define the timing for record completion: records should be filled out contemporaneously (at the time of the event or check) or within a defined timeframe shortly thereafter.
3. Create templates or standardised forms for each record type to ensure consistency, completeness, and legibility across the farm.
4. Designate a supervisor or management representative responsible for reviewing and authorising records before they are filed.
5. Include in each record the date, time (where relevant), name or identifier of the person completing the record, and any authorisation signature or initials.
6. Ensure all records include sufficient detail to allow traceability and verification by external auditors.

Storage and Preservation

1. For paper records: establish secure storage in a location protected from moisture, pests, and physical damage. Use appropriate filing systems or cabinets.
2. For electronic records: implement a documented backup system (cloud storage, external drives, or dedicated servers) with regular scheduled backups (e.g., daily or weekly, as appropriate to the rate of data generation).
3. Maintain a backup log documenting when backups occur and confirmation that the backup is functional.
4. Define a record retention schedule specifying how long records must be kept (e.g., at least 3 years, or as required by local regulations).
5. Implement access controls to prevent unauthorised deletion or modification of records.

Detection and Response to Falsification

1. Conduct regular internal audits of a sample of records to verify consistency between recorded data and actual operational conditions (e.g., cross-check recorded temperatures against independent sensor readings, verify treatment records against pharmacy stock records).
2. Train all staff involved in record-keeping on the requirement that records must be genuine and on the consequences of falsification.
3. Establish a procedure for reporting suspected falsification or misrepresentation to management or a designated ethics officer.
4. If falsification or misrepresentation is identified, document the incident including: the nature and extent of the falsification, the records affected, the likely cause, and the person(s) involved.
5. Implement corrective action addressing both the immediate falsification and the systemic or procedural gap that allowed it to occur.
6. Implement preventive action to ensure recurrence does not happen, such as: additional training, changes to the record system, increased supervision, or disciplinary measures consistent with farm policy and local employment law.
7. Maintain records of all corrective and preventive actions taken, including their implementation date and effectiveness review.

Common Falsification Scenarios and Prevention

The Interpretation Manual notes that records should genuinely reflect operational reality, including when systems fail or standards are not met. Examples of falsification would include:

• Recording water quality parameters within acceptable ranges when monitoring equipment shows exceedances actually occurred.
• Documenting health and safety checks as completed when no actual inspection took place.
• Listing feed treatments or veterinary therapeutants that were not actually applied.
• Backdating records to conceal timing of events or treatments.
• Altering mortality, escape, or production figures to misrepresent farm performance.

Prevention requires that farms acknowledge that operational challenges and deviations from standard parameters are expected in aquaculture. Transparent recording of these events—and the management response—demonstrates competent farm operations and allows for continuous improvement. Falsified records that conceal problems prevent management from taking corrective action and undermine the credibility of ASC certification itself.

Auditor Verification Approach

External auditors will verify record integrity by:

• Reviewing a representative sample of records across different record types and time periods.
• Cross-checking recorded data against independent evidence (e.g., monitoring equipment readings, supplier invoices, staff interviews).
• Assessing whether records capture instances of non-conformance, equipment failure, or deviation from standard parameters, demonstrating that records reflect actual operational conditions rather than an idealized version.
• Reviewing management's response to any identified instances of falsification or misrepresentation.

This article summarises ASC-INT-001-ASC-Farm-Standard-Interpretation-Manual-V1.0.1-September-2025.pdf. Refer to the original document for the authoritative text and full requirements.