HR Management & Compliance

Ask the Expert: Is it better to keep personnel files in a central location or on-site locally?

October 4, 2010

This is really a matter of company policy. Many companies maintain an official personnel file with copies of resumes, applications, offer letters, performance appraisals, training records, salary increases, etc. In addition, the official file should contain any contract or written agreement between the employee and the employer (such as a noncompete agreement), and all documents related to termination of employment.

Supervisors and managers often maintain their own files with notes that they can use to prepare reviews or document issues that have not yet risen to formal disciplinary actions. Some companies permit supervisors to retain copies of documents such as an employee’s performance appraisal, as long as the original is maintained in the official file.

It is important to note that some employee information is confidential, such as medical records, self-identification forms for EEOC, and I-9 forms. If any confidential information is kept at the various sites, it must be kept in a manner to ensure that it is kept private and confidential. Some laws, such as the ADA, require employers to keep medical information confidential in a file separate from the personnel file.

Additionally, it is important to keep in mind that if there is litigation or a complaint filed by an employee, all records including those maintained by managers or supervisors at various sites, will be subject to disclosure and not just what the employer labels as the official file.

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