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A file for everything, and everything in its proper file.

Personnel records and their contents are accessible to HR staff, the employee, managers, supervisors, and at times, lawyers. It is up to you, as an employer, to keep the documentation of an employee’s employment history factual and unbiased.

DO NOT place in an employee’s personnel file:
• Personal Health Information (PHI)
• Management notes including supervisory documentation and investigation material
• Employee I-9 forms
• Background check and drug testing information. SHRM recommends a separate file or placement in the employee’s medical file.

DO place in an employee’s personnel file:
• Performance reviews and formal management feedback.
• Decisions concerning promotions, transfer opportunities and salary increases.
• A balance of appropriate positive and negative information about the employee.
• Policy acknowledgements or agreement signatures

Management Notes
Strongly encourage managers to maintain a “Management Notes” file separate from the personnel file. When two managers are discussing a management decision concerning an employee, documentation of such discussion should go in this file. This information could include performance issues, discussions on promotions, and termination decisions.

It is important to distinguish that a “Management Notes” file is for storing a manager’s or supervisor’s personal documentation regarding the employee. It should not be used to “hide” things, but is a place for a manager to maintain his or her personal records of employee issues as they arise.

Management Notes are not a part of the personnel or employee file (if they are utilized properly) and an employee therefore does not have the legal right to view them, as he or she does with the contents of the personnel file.

File Locations
Assign personnel records to their appropriate locations – then stick to it. Base protocol for your company personnel records on state and Federal laws, such as the Health Insurance Portability and Accountability Act of 1996 (HIPPA), and employer best practices.

Properly train those who place documentation in employee files the appropriate way to write each type of documentation (personnel, medical, etc.).

Save you and your company future grief by storing factual, supportable employment history and personnel records in their appropriate locations.

EctoHR can help!
For a visual guide (cheat sheet!) on how to set up your employee files, including I9’s and medical files, please contact EctoHR today by calling 810.534.0170, or by email to

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