A Records Management Policy Should Restrict the Use of Supervisor Files

by on July 6, 2009 · 0 Comment POSTED IN: HR Info Center

Keep documentation centralized as part of your records management policy

You should limit or eliminate supervisor or departmental files from your records management policy. The problem here is not that there is another supervisor’s file, the problem is that Human Resources probably doesn’t know anything about it. So that leaves the company in a good bit of jeopardy if it doesn’t know what documents are being created and where they’re being stored and who is storing them.

But if you can’t eliminate the practice from your records management policy, you need to limit it in some way that you know what documents that supervisor has or you have a redundant copy of those documents. You don’t want – basically the lesson here is for the right-hand to know what the left-hand is doing.

You want to make sure that your records management policy is very careful about whether your supervisors or your individual departments are keeping personnel records separately from Human Resources or whatever other departments you have that is filing personnel records in a centralized manner.

Regarding restricting access to personnel files, which is just in general, whether it’s personnel files or medical records or whatever files you keep that have personnel information in them. People with no need to know should not access these personnel files. Literally, they should be kept under lock and key in a central area where only people who are authorized to see them can get to them.

Furthermore, access to them needs to be restricted in some manner as part of any records management policy. So for example, if a particular person wants to see a particular personnel file and they have legitimate reason to do so, the person who is responsible or the department that is responsible for maintaining the personnel files needs to know when that person has it, how long they have it for and for what purpose. And as soon as they are done with it, that file needs to be reclaimed and refiled and resecured.

Basically a good records management policy that curtails departmental files is trying to protect the company from allowing access to employee records that include personal information because disclosure of this information can be detrimental to the employee. It can cause them embarrassment. It may even lead to the loss of the job or loss of some benefits. And it can also lead to lawsuits against the employer or may be even lawsuits against the individual employees, depending on the state and depending on what happens.

So there are different – there are a number of different levels of legal protections that you have to observe here. But the general rule of thumb is just to know who is seeing those records and be very stingy with how often people get to see them.

Just know here also that employers are required to allow employee access in certain situations. Some states also mandate that employees be given access to their personnel files. However, not all states do. So if you’re in a state where the employee is not granted access to their personnel file, depending on state law, you may be able to deny the employee access to their personnel file.

A lot of times, it is just assumed that if an employee or former employee wants to see their file, that they are absolutely entitled to do so. That is not necessarily the case. So you need to check your state law depending on where the request is made to see whether the employee must be given access to their file.

Edited Remarks from “Personnel Document Retention: What to Keep, How to Keep It & Why It Matters” by Matt Gilley

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