Retention of your HR Personnel records – Part 2 of 5
In part 2 of this blog series (you can read part 1 here), we will look at retention for HR personnel files. We’ll talk about using Big Bucket retention instead of granular listing, and the sinister side of HR.
Retaining HR Personnel files
On your retention schedule, you will need to use the big bucket categories that are relevant to you (see part 1 for these categories). There tend to be three retention periods to think about, and these should be balanced with your corporate risk:
Last action/entry plus 6 years (in Big Bucket retention, this applies to the whole file except specific items that need to be kept for a long time)
Last payment of pension plus 6 years.
Date of Death (DOD) plus 6 years (if the person doesn’t have an organisational pension).
Long HR Personnel Retention
There is a consideration that if you don’t hold your pension internally, you may want to consider applying the latter retention. However, I have noticed that there is often a disregard for the difference between internally and externally, as there is a huge risk to the organisation not being able to facilitate someone’s pension if they no longer have the records. Therefore, you should consider only applying the retention of no pension if they have opted out.
This retention period can be an awfully long time because the retirement age is no longer a set date and people are working for longer. Moreover, some pensions can be passed through to dependents. An example of this is an NHS pension, where an active pension member dies in service. There is also a child pension that can be drawn until the recipient’s 26th birthday. I know this because I was a beneficiary of one.
The only way you could confidently calculate a long enough retention period is to take the subject’s Date of Birth (DOB) plus 122 years (oldest living person) plus 6 years. Thereby making the retention period DOB plus 128 years. This is pretty rough retention and doesn’t really work out in practice. You may end up keeping some records longer than you should because the subject dies sooner, or worse, you destroy the records before they have finished their last payment. Although we haven’t had a 128 old person…yet.
Age and Access to Vulnerability
The likes of Buster Martin who is 104 and still working.
Despite being a habitual drinker and regularly smoking twenty cigarettes a day, Buster still managed to become the UK’s oldest worker at 104 years old.
Buster worked as a van cleaner for a plumbing company in London, where his work ethic inspired other members of staff to step up their game. He almost never missed a day at work, even reporting for duty on his 100th birthday.
I don’t know Buster and on the face of it, Buster could be a perfectly law-abiding individual. The chances of Buster having access to vulnerable children or adults as a van cleaner for a plumbing company are minimal and therefore risks are low. However, what if the vans belonged to the NHS or a school and he was issued with a staff card? Buster then has the potential to come in to contact with the general public and it’s a different situation.
For a more sinister look at age and access to vulnerable people, we have the example of Jimmy Saville and the criminal activity that came to light after his death. The lesson is that you really need to be consistent when assessing record retention for HR files and deciding on the best retention to apply.
On that note, I’ll bring this second part to a close.
Parts 3, 4 & 5
3. Dealing with the HR backlog
4. Deciding what HR records to scan, going paperless in HR and balancing risk
5. Moving forward and keeping it managed
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