Managing your HR Personnel Records effectively – Part 1 of 5

Human Resources (HR) or Personnel files refer to the records required in every single organisation that hires staff or contractors.  This applies whether they are temporary or permanent. For the purpose of this blog, when I refer to ‘staff files’, I mean the people who are on your PAYE.

Do you find that you are retaining staff files for too long? Many HR managers are reluctant to destroy old records but, if you forget about these records, you are risking your compliance with the Data Protection Act 2018. In this series of posts, I will guide you through the effective and useful management of your PAYE staff files.

Retention

Traditionally, a record manager will group their files by record series.  They will produce an accompanying retention schedule with a detailed enumeration – sometimes described as a granular listing – of the records with specific disposition instructions.  People usually group their HR records by the employee. HR managers update these files on a regular basis and they may contain progressive record series such as disciplinaries.   The evolving nature of these files means that you cannot apply one solid retention policy to a record series.

For HR records we need to use “Big Bucket Retention”.

Big Bucket retention is where the end-user has fewer categories of retention to pick from.  The advantage of Big Bucket retention is that we are likely to classify records correctly when we have fewer choices.  Other benefits include simplified user training, and easier review and revision of retention schedules when incorporating a new record series. HR practitioners can rely heavily on paper-based systems and, when a staff member leaves, their records are often placed in an offsite storage facility.  It would be expensive and time-consuming to pull files for regular review and remove individual documents that have expired.  It’s far better to apply a retention policy to the whole file.

Granular listing works well for electronic systems where each item is flagged for disposal automatically, but Big Bucket retention is generally better for HR!

Standard Big Bucket

You can place most HR records into one of  five categories:

1. Unsuccessful candidates
2. Current staff
3. Staff who have left your organisation in the last 6 years
4. Former staff who have left your organisation over 6 years ago BUT who could still potentially work with vulnerable adults or children
5. Staff who are no longer working (usually age 80+) and are not drawing from an internal pension scheme

Other Potential HR categories:

Pensions

• Staff who no longer work (usually age 80+) but are drawing down a pension (internal pension scheme)
• Staff who no longer work (usually age 80+) but are drawing down a pension (external pension scheme)

Deceased

• Staff who are deceased for six or more years.
• Staff who are deceased for less than six years.

Both Pension and Deceased

• Those staff who are deceased, but have a pension to be drawn by a dependent or spouse

When the Equality and Diversity Act 2010 came in, the retirement age was removed, so there is no longer a standard retirement age to calculate retention from. Former members of staff may choose to work well into their senior years, and their roles may give them access to vulnerable children or adults.  You should determine the basic sensitivity of the records and consider how likely it is that they will be required.

Retention for each of the HR categories:

• Unsuccessful candidates.  You should retain their CV, application form, interview notes and exam answers etc. in line with the Equality and Diversity Act 2010.  This allows candidates to lodge a complaint up to one year after their interview if they feel the process was unfair.
• Current staff.  No action is required until they leave your employment.
• Staff who have left your organisation in the last 6 years.  You should work through these records, as they form your backlog.  We’ll look at how to deal with this backlog in Part 3 of the blog series.
• Members of staff who have left your organisation over 6 years ago BUT who could still potentially work with vulnerable adults or children. You need to destroy anything that is not required for the long-term. This also forms part of your backlog.
• The ex-staff who are no longer working and are not drawing a pension. You need to remove these records completely and retain a skeleton entry* indicating that they once worked for you.
• Ex-staff that are no longer work and are drawing a pension. You need to remove all records except for their pension information and a skeleton entry.*
• Former staff who are deceased.  You will need to check if there is a pension being drawn down but, after 6 years, you can potentially convert their record to a skeleton entry.*

*The skeleton entry can be as simple as a name, unique ID,  employment dates, employment location(s) worked and reason for leaving (resigned, fired, redundant, TUPEd etc.).

Coming next in HR Part 2, 3, 4 & 5

2. Age, Vulnerability and Retention

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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