Human Resource Services News

:: Deidre Siegel
Director, Human Resource Services
G. R. Reid Consulting Services, LLC
Read about G.R. Reid Human Resource Management Tools 

Employee Personnel File Audit
Employee personnel files contain sensitive materials that only few may access. It is important to audit personnel files each year to make sure that those who have access to the file are able to view only what is necessary. For example, the payroll department should not have access to an individual’s I-9 or to any write-ups that the employee receives. Additionally, the benefits department should not have access to employee’s W-2 form or to the employee’s attendance calendar or time-off requests. With this in mind, personnel files should be separated into different sections to allow for ease into the file depending on who is allowed access to the file. The Society for Human Resources Management outlines what should and should not be accessible and by whom. The following is a description of the outline:

Personnel Records may include:
    •    Documents used in recruiting, screening, and hiring candidates
    •    Job descriptions
    •    Written documentation of actions taken during course of employment including promotion,
         transfer, demotion, layoff, termination, etc.
    •    Pay and compensation information
    •    Education and training documents
    •    Receipts of handbooks, employment-at-will disclaimers, policies, etc.
    •    Employee recognition programs
    •    Warnings, disciplinary actions, counseling
    •    Drug test policy acknowledgement and consent form
    •    Background check consent form
    •    Safety training acknowledgement
    •    Sexual harassment training acknowledgement
This section should be visible only to the employee, supervisor with a need to know, former employee, and/or Human resources.

Medical/Confidential should include:
    •    Medical information, enrollment forms, waivers of coverage
    •    FMLA documentation (can be kept separate)
    •    Disability documentation (can be kept separate)
    •    Doctor’s notes
    •    Workman’s compensation documentation (can be kept separate)
    •    Leave of absence documentation
This section should be visible only to Human Resources, supervisor as needed for reasonable accommodation, and/or Government/legal agencies conducting investigation relevant to medical issues.

Payroll should include:
    •    Any payroll changes including bonuses, promotions, demotions in pay, reimbursements
    •    Any deduction information that should be included in employee paycheck such as benefit
         deductions amounts
    •    W-4, garnishments, levys, child –support
This section should be visible only to payroll staff, Human Resources, and/or Auditing/investigating agencies.

The following should always remain separate:
    •    I-9
    •    Investigation notes and reports
    •    Any drug tests or background check results.
This section should be visible only to Human Resources, and/or Auditing/investigating agencies.
These sections can be modified based on the specific documents and who is allowed access to each file. Some documents may contain more information than others, such as social security numbers, which may be kept separate from other information. Files should be kept consistent, locked up in a file cabinet where files cannot be tampered, and all information accessible should be kept confidential at all times. If at any time there are any questions or discrepancies, state and federal laws should be researched to confirm compliance.