Deciding what HR records to scan: Going paperless in HR and balancing risk
HR records are a tricky beast and they like to hang around in paper form. I have been involved in several paperless HR projects and, all too often, people’s first instinct is to scan everything.
The main problem with scanning is that it’s expensive. It’s also difficult to estimate for scanning budgets when you’re dealing with files of varying sizes.
Knowing what you should scan, and why, is of huge benefit to any organisation. You will also benefit from changing your processes so that you stop creating paper documents. 99% of HR documents can now be created by a computer, lessening the requirements for physical storage.
I would categorically say, and feel free to quote me…
“Do not scan all of your HR documents. Don’t do it. It’s not worth it!”
Back scanning past records for people who no longer work for your company is a waste of money. They will sit on shelves until you eventually destroy them. You only need to scan these records if the subject reenters employment, if request their data under the DPA, or if an investigation is to take place.
Your priority is to consider your current records. You won’t go wrong by scanning every active record, although you could break this down even further and only scan records for permanent staff members. This means you will weed out fixed-term, temporary, short term and bank type contracts.
If you have the time, go through and sort the records first. You can separate out the records for long retention and place these at the front of the file. If you’re wondering what parts I’m talking about, see Part 2 of this blog series. That post looks at the types of documents you should consider keeping for a longer retention period than the rest. These can then be scanned as two PDFs which enables you to apply decent retention with no further activity on your part.
Time is money
If you don’t have time, you can request assistance from your scanning provider. If the provider has the capability, mark specific pages within a PDF and have them extracted into another file – this is the most environmentally friendly option. Failing that there are workarounds but, whatever you do when you scan records, you need to consider the legal admissibility and evidential weight of records. Will you need the records in a court scenario? If so, have you followed a strict process to ensure that the files haven’t been amended.
Remember that getting a certificate for legal admissibility isn’t about the organisation. It’s about one specific process and using specific types of equipment. If you change your equipment, whether it be an update or a replacement, you break the chain and need to start again. If you’re having your scanning carried out by an external body, will need to know if the company is making any changes to its process or equipment. In the event this happens, you’ll need to audit it appropriately and get the supporting documentation to update your records. Don’t give anyone the opportunity to discredit you or have your records thrown out in the courtroom! No one has ever had their digital records thrown out, but no one wants to be the first either.
Paperless is not something to aspire to
Any aspiration to have a paperless environment is not realistic. Why scan records that you’re never going to use just to get rid of paper? There’s nothing wrong with drawing a line in the sand for certain types of records. Instead, having the aspiration to remove paper over a certain time period and making improvements to reduce paper instead is a much better approach.
‘Paper lite’ is a much more realistic approach. For example, using paper during the recruitment process can be much more practical. If you’re interviewing, you’ll probably want to scribble notes about the candidate and it’s way more complicated to add a laptop or iPad into the mix. You only need to keep records for an unsuccessful candidate for one year. Scan the successful applicant’s recruitment paperwork straight into a file you create for them. Why add extra admin into the process when it can be so straightforward? If you plan to keep any CVs for future job openings then you can create a digital version of these. On the whole, you should deal with whatever paperwork comes your way.
Gently does it
Before making any decisions about the destruction of your paper files post-scanning, consider whether they may ever be needed as evidence in court. Always have your processes externally audited by someone who knows British Standard BS10008:2020. Always get approval and sign off from senior management before you destroy anything. This is a decision your SIRO should be comfortable with provided you can demonstrate the processes and procedures that you followed.
Balance the risks and ensure that your records have not been edited between the physical and electronic copy. Think about how you should spend your time, effort and money – what things are less risky to keep in a physical format when they’re no longer in use. Think about changing your processes and moving from pen to mouse, it’s less risky than relying on scanning. Change the way you do things rather than changing what’s you’ve already done. Go digital by default rather than pencil by default – the risk of what you do and don’t scan will be less of a problem.
In the final part of this blog series, we look at staying paperless, sticking to your HR record management guns, and anticipating future problems.
You can arrange for Emily to undertake an audit of BS10008:2020, or for assistance with your HR records management: Contact Emily.
The above is not legal advice, please always check with a legal representative.
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