Personnel files: dos and dont’s

If you have employees, then I’m guessing you have employee, or personnel, files.

I’m also guessing that, unless you’ve been paying very careful attention to what goes in those files and how they’re organized, they’re a bit of a mess. Unfortunately, it’s not hard for this to happen. Managing employees takes a lot of paper, even in this digital age.

Why not make it your New Year’s Resolution to get your personnel files in order once and for all? (No, it’s not too early.)

Here are a few do’s and don’ts to keep in mind as you move forward.

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  • Do purge the files of unnecessary duplicates. What is it with HR professionals and multiple copies? Yes, it’s a good precaution to photocopy originals before sending them out for signature, but once the original, signed copy is returned and filed, the copy needs to come out of the file and go into the shredder.
  • Do separate and store information by topic. Payroll information shouldn’t mingle with performance evaluations, which shouldn’t mingle with leave requests, which shouldn’t mingle with new-hire information, and so on. Multi-section folders are the way to go here.
  • Don’t allow managers to place in the file disciplinary notices, written reprimands, and other “negative” documentation the employee has never laid eyes on. You might be surprised to learn how many times I’ve said “no” to a manager trying to sneak a little something into the personnel file of an employee on the outs. Come on, dude! Talk to your employee like a grown up, already.
  • Do remove any medical information from the files. Both the Americans with Disabilities Act (ADA) and the Genetic Information Nondiscrimination Act of 2008 (GINA) require that employers keep medical information confidential, and generally, placement in a personnel file doesn’t meet that standard.
  • Don’t encourage managers to keep their own “personnel” files. A better policy is that all original documents go in the company files (no exceptions) and managers go through HR when they have legitimate reason to examine employee data. And speaking of which …
  • Don’t allow willy-nilly access to the files. Have clear policies as to who can review the files (or the information in the files) and under what circumstances.
  • Do review both your state and local laws to ensure your compliance.
  • Don’t put things in the file managers shouldn’t see—child-support judgments and IRS garnishments are examples of two types of data that could seriously prejudice a manager against his employee, and honestly, it’s none of the manager’s business.
  • Finally, do regularly review the files to keep them in good order for your next audit or employee request.

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