HR File Management 101 – What To Include / Exclude From Employee Personnel Files

An Introduction To HR File Management

Maintaining well-organized and compliant employee personnel files is a crucial part of effective human resources management. Whether you’re a small business owner or an HR professional, knowing what to include (and exclude) in these files can help protect your organization from legal risks, ensure compliance with labor laws, and streamline employee record-keeping. 

Regulatory bodies like the Americans with Disabilities Act (ADA), Equal Employment Opportunity Commission (EEOC), and Fair Labor Standards Act (FLSA) have specific requirements about the types of documents that must—and must not—be stored in personnel files. In this guide, we’ll cover the essentials of personnel file management, including access permissions, compliance considerations, and a detailed breakdown of what should and shouldn’t be included.

What Should And Should NOT Be In Employee Personnel Files

While it may be convenient to store everything about an employee within their personnel file, this is absolutely NOT the best practice! 

The employee personnel file should contain only documents which refer to the employment relationship between the employee and the employer from application through termination. The employee personnel file is a highly sensitive file containing confidential information and should be treated as such by limiting the accessibility to the file only to those required to access it (employee’s immediate supervisor and Human Resources). The employee also has the right to request access to their own personnel file but at no time should the file be removed from the oversight of Human Resources!

The American with Disabilities Act (ADA) forbids employers from including medical information such as reasonable accommodation requests, doctor’s notes, and workers’ compensation claims within an employee’s general personnel file. These documents must be maintained separately from the employee personnel file and must maintain an even higher level of security. 

Federal I-9 forms should be kept separate from all other records and in one common location (confidential and protected folder in locked filing cabinet or confidential folder electronically with restricted access). 

In addition to the above documents, there are also other records that should not be accessible to managers and supervisors due to the sensitivity of the information including documents that contain dates of birth, social security number, marital status, dependent information, immigration status, race, gender, religion, sexual orientation, national origin and criminal history. A common solution to this challenge is to maintain an additional file that contains these records and limit the accessibility to these records to Human Resources and the employee. 

Minimally, there should be four separate files storing sensitive information for your employees: Personnel File, Confidential File, Medical File and Benefits File. There should also be one common file for ALL I-9 forms including forms for terminated employees, hires, and re-hires. 

The first question when considering where a document should be stored is what the intent of the document is. Below are common types of documents and where they should be stored:

Employee Personnel File

Employee Confidential File

Employee Medical File

Employee Benefits File

Conclusion

Proper personnel file management isn’t just about organization—it’s about compliance, security, and protecting both your employees and your business. By maintaining clear, structured records that align with HR best practices and employment law requirements, you can reduce liability, improve efficiency, and support a professional workplace. Regular audits of your personnel files help ensure you’re up to date with regulations from the ADA, EEOC, OSHA, and other governing bodies. 

While we’ve tried to cover the basics in this blog, there is so much that goes into a successful HR file management system, and each of our clients utilizes a custom tailored solution that caters to their particular industry and business structure. If you need help managing HR compliance and record-keeping, know The Buzz HR is here to help. We simplify your HR processes, keeping your business organized, compliant, and ready for success. Inquire on our website or feel free to call us if you’ve been stung by an HR problem!