Division of Personnel Files & "sensative" information

annmarie

I need information on the division of personnel files and what is considered "sensative" information. How should an employee's files be divided? I understand everything cannot be kept in the same file, but how should it be divided? Anyone know of a standard procedure to follow?

sohappytobe

I have three separate files for each employee, kept in three separate cabinets, all under lock and key (1) Personnel File (2) Medical File (3) Benefits File. I have been through 8 JCAHO surveys and have not had any problems with this file order yet.

mushroomHR

I too have three separate files kept under lock and key: 1) payroll file, 2) medical/benefits file whick contains confidential information only available to me and the safety manager, and 3)a general information file where I keep attendance records, signed receipts, warnings, etc.

Don D

The Americans with Disabilities Act is the only law that requires you keep things separate and that law applies only to 'medical files'. The other file divisions you opt for, or others opt for, are based strictly on your business decisions. No magic involved. Some separate out the I-9 files so that an investigator who is doing an I-9 audit won't have access to the general files. There is also disagreement over what 'separate' means. Our personnel filing cabinet is organized in alpha order with three manilla files in an accordion file for each employee: Medical, work related, personal. It's technically separated and all three are available to nobody outside HR. If a supervisor/manager has need for the work related portion of a file, HR will pull it and hand it to him/her for review.

We can argue all day over whose system is best and what 'separate' means; but, the bottom line is that the law requires only that medical be separate from the rest of your personnel file. I can also tell you that some processes are so anal as to require you to go to 5 or 6 different locations to pull together a total personnel file. The only reason for filing is for retrieval. The smoother your retrieval process, the more functional and successful your department will be.

POPEYE

Don is absolutely correct. We have gone 1 step farther and do have a separate (physically different filing cabinet) I-9 file because of the reasons mentioned.

sohappytobe

The only thing I have to add to that is that medical information is also kept in benefits files, i.e., applications for insurance where medical questions are addressed. That's why I keep those separate as well.

Whirlwind

Don, what kinds of things are in the "personal" category?

By the way, I like your idea of the "files within a file."

Don D

>Don, what kinds of things are in the "personal"
>category?
>
>By the way, I like your idea of the "files
>within a file."


The things in the 'personal file' are just the mundane, standard forms used to sign people up for employment, their background check, boring stuff otherwise, demographic drivel, nothing particularly related to their job or performance. Personal stuff. And I can tell you from many years of experience that you do not want to go to seven locations to assemble a complete file for a hearing, whether it be comp, UI, EEOC, other DOL, whatever.

mushroomHR

My understanding of keeping medical files "separate" from other files is that the medical files are required to be in a "separate" filing cabinet, not a "separate file" within the same filing cabinet. This would prevent a department supervisor who may have access to say attendance files, from going into that filing cabinet and accessing the medical files even though they are in a "separate" file from the attendance files but still in the same filing cabinet.

POPEYE

As Don alluded to in his earlier post, if ALL files are secure, there is no need to have them in a totally separate cabinet or across the hall. If they are "separated" by a manila folder is sufficient. However, if as you said, if supervisors or managers have access to the files, then yes, the medical file should be totally separated.

sohappytobe

JCAHO and State surveyors have required me to have them in separate filing cabinets so that only HR and the infection control nurse may have access to medical files. If supervisors have access to HR personnel files and medical files are in the same cabinet, then they also have access to medical files, which is a no-no according to those agencies.

Whatever

We have a separate file for all medical information. We have all I-9's together. All other info is kept in a partition folder.

Rockie

I agree with Don. I only keep the medical file separate. I don't have time to make all these files or paw through several files when I need to look for something. My personnel file is divided into sections so that I can categorize items such as hire information, performance appraisals, personnel actions, forms, etc.

marc

We have the medical files in a separately locked cabinet because specific managers can access the general personnel files. The I-9's are also separated.

Don D

It's interesting that most of you seem to accentuate the word 'locked' as if some employees are actually going to try to access the personnel files. We have ours in an office with a locked door, but we don't obsess about locking up stuff.

mushroomHR

Unfortunately I don't have the luxury of an office. My desk is in full view of everyone and so are my filing cabinets. That's why I have to have cabinets that lock and remember to lock them all before I leave at night.

Don D

Watch for the UPS truck. I'm shipping you four pre-fab walls, 16x18, one with window and drapes, one with locking door, one with mural of wheatfield, one with dartboard. Requires some assembly. Tools required: phillips-head screwdriver, wrench, bottle of wine. x:-)

POPEYE

Don't forget to send the hammer. You can't put anything together without one.

Don D

Depends on how thick that wine bottle is and how quickly it empties.

mushroomHR

Thanks Don D. I can't wait for everything to arrive so I can assemble (and imbibe). x:-)

2445428

I keep personnel records in locked "Personnel File Cabinet"; medical records, including supplemental insurance electives, in a separate locked cabinet; attendance records in a locked "Attendance File Cabinet"; and 1 accordian style folder with all I-9 in my locked "Medical File Cabinet." The rationale for separate file cabinets for the above is to minimize the exposure of records to only those needed by an official visit from let's say DOL, etc.

mwild31

Here's my system:

Medical/Benefits files

Personnel files (they're six-part folders) - personal stuff, applications, reviews, emergency contacts, etc.

401(k) files (a four-part folder)

Worker comp. files.

I-9 binder - one big binder for all, arranged alphabetically

Payroll information is kept by the accountant.

We have an open office, so all of our cabinets have to be locked. The personnel files, the 401(k) files and the I-9 binder are all kept in one file cabinet (although different drawers). The Medical/Benefit and Worker comp. files are kept in a separate cabinets.