Personnel Case Files: The Case For Using the Standard Information Banks

by: Bill Manning, National Museum and Science Technology Corporation

Although today’s focus in Records Management is on the application of established principles to documents in electronic format, it is also evident that Records Managers will continue to be responsible for records maintained in the more traditional paper-based format, including case files. The arrangement of case file systems is typically less complex than hierarchical subject-based systems, and the identification of documents less challenging than subject block classification. In most cases, the files are created and maintained by the client division while they are still active. Notwithstanding this, these records contain important information, and Records Management staff are usually responsible for their custody and coordination during their life-cycle once they enter their semi-active or dormant stage. Proper case file management remains an important component of an effective overall Records Management program.

Of all case file systems handled by Federal government institutions, Personnel files are the most complex, and the consequences of mismanagement are the most far-reaching. The Standard Information Banks (see Introduction to Info Source: Sources of Federal Employee Information 1999-2000; Treasury Board Secretariat, Ottawa, 1999, pp.xxvii - xxxiii) attempt to divide personnel documents into categories, each of which is provided with its unique Retention and Disposal Standard. The arrangement provides for an Employee Personnel Record Bank Number (PSE 901) file for each individual, which will contain important documents relating to such things as career development and information vital for the calculation of pension and superannuation benefits. The personnel or employee file shall be retained by the employing institution for the duration of employment plus one (1) year; the institution shall then transfer it to the National Archives’ of Canada Federal Records Center (FRC) in the National Capital Region (Building 18, Tunney’s Pasture). The National Archives will destroy the civilian personnel file when the individual turns eighty (80) years of age or two years after the individual’s death, assuming there is no further action pending. The new retention and disposal 98/005.

The other information banks are intended to contain records for comparatively short periods and stay with the employing institution pending disposal. While the legislation requires Federal government institutions to manage the records according to the above-noted Retention and Disposal Standards, there is no specific obligation that the records be organized in such a way as to mirror the Standard Banks while active. The question is often asked, even by Human Resources professionals: "why do we need to maintain several separate files for one employee? Why can’t we keep all their documents on just one file?" What follows is a brief summary of how I respond to this question.

1. Varying Retention and Disposition Requirements: the retention periods for the information banks vary from the lifetime of the individual (Employee Personnel Record) to as little as 2 years for many of the others. One can expect to find monthly or weekly attendance records on the Attendance & Leave (PSE 903) case file and short-term pay calculations on the Pay & Benefits (PSE 904) file. These records are of comparatively transitory importance as long as the information they contain is compiled into summaries which are located on the Employee Personnel Record file (a yearly Statement of Leave Credits, for example). By the same token, the materials documenting the administrative aspects of employee training (Training & Development - PSE 905) are not nearly as important in the long term as the certificate or diploma earned by the employee, which should be placed on his or her Employee Personnel Record file to document his or her credentials. While a letter of discipline is a serious matter and should be placed on the employee’s Employee Personnel Record file, there is no justification for including the forms, letters and notes compiled during the investigation. It makes more sense to retain these on a Discipline (PSE 911) case file for 2 years, after which both the file and the letter on the Personnel file are destroyed. In some cases the retention period is calculated from a specific event, as with the Discipline file, in some cases from the end of a specific period, such as a review period for Performance Reviews (PSE 912). In other cases it is calculated from the separation, or Struck of Strength "SOS" date. If we choose to maintain separate files for documents with specific retention periods and disposition requirements, it is much easier to identify the files and dispose of them based on legislation, policies, and best business practices. The alternative, to screen one Personnel file and remove specific documents for destruction, would be time consuming and would increase the possibility of error, making the application of retention schedules less efficient.

In most cases, retention schedules indicate minimum retention periods. In a few cases, the retention period is a maximum time limit, after which the record must be destroyed. Failure to do so is a violation of the rights of the employee as guaranteed under Privacy Act, and may leave the employer open to the possibility of litigation. The two obvious examples are Performance Appraisals (5 years) and Discipline records (2 years providing that no further action has been recorded in that period). Again, the act of identification and removal is easier and less prone to error if those specific documents are kept separate. Conflict of Interest documents should be kept separate from all other records because the Post Employment Code remains in effect for the benefit of the employer for 2 years following the employee’s departure. It therefore follows that the documents should remain with the employer for that period so they are available to ensure compliance, and should not follow the Employee Personnel Record file.

2. The Need To Know Principle: The second argument in favour of sub-categorizing personal information follows from the fact that different people need to see different records for different reasons. Few would argue that the Head of Pay & Benefits is not justified in reviewing monthly records of hours worked to calculate leave credits. But what if the employee’s latest unfavourable appraisal or a letter of discipline was clearly visible on the same file? That person has no need to be made party to that information in carrying out his or her duties. Furthermore, if the appraisals are on a separate file, they would be in the File Room where they are protected from inadvertent loss as well as unauthorized disclosure. During this period they are also available to a Human Resource Advisor or Staffing Officer who has a legitimate requirement to review them.

It also follows that with one all-inclusive Personnel file, one is compelled to "put all your eggs in one basket." In the event of a lost or misplaced volume, all your records pertaining to that employee are lost. With specialized files, the impact of a lost volume is minimized.  

3. Ease Of Retrieval: This means that sub-dividing the records of an employee by subject simply makes good sense from a records management perspective. In addition to having different retention intervals, different disposition requirements and needing to be used by different people, some documents tend to consume more space and are more or less important than others. By setting up personnel case files using the same structure as the Standard Banks, one ensures that the important documents end up on the Employee Personnel Record case file. The others are of comparatively transitory or short-term importance, and are often more voluminous. It makes little sense for a user to be required to go through mountains of monthly attendance reports and hourly pay calculations in order to find a copy of the employee’s personal resume or confirmation of previous employment. Not only is this frustrating, but the alternative ensures that specific documents can be found more quickly and accurately.

4. Legislative Requirements: All Federal Government Institutions, including Crown Corporations, are subject to the provisions of the Privacy Act (as well as Access legislation, the Financial Administration Act, the National Archives Act, Management of Government Information Holdings Policy (M.G.I.H.), the Government Security Policy, etc.) As previously noted above, the institution is under no obligation to organize personnel records according to the Standard Information Banks, but they are responsible for ensuring that the retention and disposition standards associated with them are respected. The easiest way to ensure that this can be done as efficiently as possible is to adopt the arrangement outlined in the Standard Bank Descriptions from the beginning of the process. The institution retains the flexibility not to adopt banks of information where there is insufficient documentation to justify the effort. For example, the National Museum of Science & Technology Corporation does not issue parking permits (Parking PSE 914) or administer its own medical files (Occupational Safety & Health PSE 907), so creating these systems would obviously be futile. The National Personnel Records Center reserves the right to refuse to accept records for separated employees that do not fit into the description for Employee Personnel Record (PSE 901). The implication of this is that if an agency were to maintain one personnel file for each employee, the file would have to be carefully screened, and much of the contents removed before it could be forwarded to the NPRC following employee separation.

My experience has shown that dividing up employee personnel case file records to reflect, within reason, the organization of the Standard information Banks, is a sound strategy from a records management perspective. The underlying intention is to ensure the preservation, protection and availability of important personal documents while facilitating the systematic separation, short-term use and disposal of those that are less critical in the long term. It ensures access while minimizing the possibility of loss or error. While the apparent profusion of files pertaining to one individual may at first seem excessive, the benefits will far outweigh the disadvantages.