Supplemental Information Print this PDF

Name: Employee Records Policy
Responsible Office: Human Resources Office

Applies to: (examples; Faculty,Staff, Students, etc)

Faculty , Staff , Students

Policy Overview:

Issued: 10-01-2014
Next Review Date: 06-10-2023
Frequency of Reviews: Every 5 Years

Maintaining necessary employment records in an appropriate format is vital to the operation of the University’s payroll, benefits, employee management systems and compliant with legal recordkeeping requirements. 



Maintaining necessary employment records in an appropriate format is vital to the operation of the University’s payroll, benefits, employee management systems and compliant with legal recordkeeping requirements.


1. Policy

a. The policy of the Office of Human Resources pertaining to access to records maintained in Human Resources safeguards against improper disclosure and protects employees’ rights to privacy. Records about the employment of student are considered employment records under the Family Educational and Right to Privacy Act.

Individually identifiable personnel records, performance ratings or records pertaining to employees or applicants for employment, and records of hiring, firing, disciplining or promoting an employee of the University are and shall be considered sensitive.

The institution generally supports employees accessing Personnel Files. Access to records may be granted to individuals under the following circumstances:

• The employee who is the subject of the file requests to view their personnel file. Employees who want to review a file with a representative such as an attorney or financial planner should schedule an appointment with Human Resources.
• Supervisory employees who are considering the employee for promotion, transfer, reassignment, demotion, dismissal or other personnel actions.
• A University attorney or other appropriate officer when needed in connection with any action brought by the employee against the University
• Other persons acting in compliance with federal, state or local laws such as auditors, equal employment opportunity investigators, etc., or in response to a lawfully issued subpoena or court order.
• University supervisory or administrative personnel who can reasonably establish a need to know in order to perform the duties of their position.
• Security and emergency response personnel will be given access in connection with emergency or safety and security matters.

The file shall be reviewed in the Office of Human Resources in the presence of a member of the Office of Human Resources staff. Employees may take notes or request copies. Employees have the right to insert concise information in their files in response to material they deem unfair or incorrect.

It is the policy of the University that former employees are not entitled to access their closed personnel records (absent subpoena or other legal process), nor may they access the personnel records of any other employee whether former or currently employed.

2. Procedures

a. In order to provide management with appropriate information to base personnel decisions upon, an Employee Records File must be maintained. Such files are required to be maintained securely either in password protected digital files, or in physcial files with mutliple physical barriers (i.e. locking cabinet and locking room) to assure privacy and security. Some information may be maintained electronically (emails or performance review forms for example) provided data is retained according to policy specifications and privacy and security is present at a level at least equivalent to how paper records are maintained. The contents of such files should be maintained in accordance with current records retention schedule. An Employee Records File shall consist of: the Personnel File (which includes Sensitive and Non-Sensitive folders); the Worker’s Compensation File; the Family & Medical Leave Act (FMLA) file; and the Benefits File. There will be separate files within the Personnel File. Specific pieces of information are to be maintained in each separate file. Electronic information in these categories may be separated by separate screens, file folders or other methods. 

Departments may maintain separate records pertaining to employment matters, but are subject to the same recordkeeping and records retention timeline as outlines in section m of this policy.

b. Items maintained in the employee Personnel File should include but not be limited to:

Non-Sensitive File- 

• New Hire Checklist(s)
• Notes to file (including emails)
• Curriculum Vitae/Resume
• Additional Employee Information Form
• Code of Ethical Conduct Form
• Consent to Criminal Background Check Form
• Consent to Credit/Background Check
• Tuition Reimbursement Forms
• Achievements
• UHSP and/or Pharm CAS Applications
• Student worker application form

Sensitive File- in general, these records contain information such as date of birth, social security numeber or salary information.

• Personnel Action Request—original
• Tax Forms
• References
• Direct Deposit Form 
• Offer Letter/Appointment Letter (Contracts)—original
• Employment Application
• Interview Notes
• Annual Plans
• Performance Reviews
• Issues/Concerns
• Tenure, mid-tenure and promotion review documents
• Disciplinary Documents
• Employment Verifications
• Extra Compensation (consulting, classes, etc.)

c. Information that should be maintained in the Family and Medical Leave Act (FMLA) file include:

• Notice of Eligibility and Rights and Responsibilities
• Certification of Health Care Provider
• FMLA Employee Request
• Physician’s Statements
• Medical Clearance to Return to Work

d. Information that should be maintained in the OSHA/Worker’s Compensation file includes:

• Injury Report
• Medical Authorization Form
• Worker’s Compensation Investigation Report
• Witness Statements
• Immunization records or declination form

e. Information that should be maintained in the I-9/Immigration File incudes:

• I-9 forms, and scans or copies of employment documents
• E-Verify documents 
• Visa, immigration or sponship records 

f. Information that should be maintained in the Disability/VEVRA File includes:

• Self-Identification Document
• Disability and Veteran Information such as Form CC-305 and VEVRA form

g. In addition, completed Background Check Reports will be kept by The Office of Human Resources in a separate file.

h. The information maintained in the Benefits File will not be considered as part of the employee’s individual personnel file. This information will be accessed only on a need to know basis.

Benefits File-

• Benefit Summary
• Medical Enrollment Forms
• Dental Enrollment Forms
• Vision Enrollment Forms
• Cafeteria Plan Enrollment Forms
• Life/ AD&D Insurance Enrollment Forms
• Long Term Care Enrollment Forms
• 403B Enrollment Form and Salary Deferral Form

i. Investigation records or notes that do not result in an employment based action (documented warning or other action) remain a separate confidential file in Human Resources.

j. If needed paperwork is not submitted in a timely fashion delays in processing changes may occur. HR will work with department officer responsible for the employee to get all needed paperwork. Failure to comply or assure compliance with the requirements of this policy may result in HR notifying the department officer’s supervisor of a failure to support compliance efforts; this could be noted on the performance evaluation.

k. Chief Human Resources Officer, or their designee, will collect information by means of a tracking log located in the Office of Human Resources to determine who received access to the personnel file(s).

l. The Chief Human Resources Officer will be responsible for ensuring a periodic audit is conducted to ensure compliance.

m. The retention periods apply to both electronic and paper-based records:

• Personnel: 7 years after termination, files involved in legal claims files will be retained indefinitely until the risk has subsided or the matter has been resolved.
• Medical/benefits: 6 years after the plan year
• OSHA: 30 years
• I-9 Forms: Not more than 3 years after termination
• Hiring Records: 2 years after hiring decision




President, Assistant Vice Presidents of Advancement, Information Technology and Human Resources, Vice Presidents of Campus Life/CDO, Finance/CFO, Marketing and Enrollment Services, Operations, Director of Athletics

Copying documents and ensuring that the documents covered by this policy (originals or copies) are retained according to the policy and delivered to HR.


Copying documents and ensuring that the documents covered by this policy (originals or copies) are retained according to the policy and delivered to HR.

Adacemic department chairs and Director of Experiential Education

Copying documents and ensuring that the documents covered by this policy (originals or copies) are retained according to the policy and delivered to HR.

Payroll staff

Ensuring that the necessary documents (originals or copies) are delivered to HR and potentially copying documents.

Policy Contacts:


Contact Information

Dan Bauer




Supplemental Information: