Whoever does HR in your organization will obviously need access since they’re responsible for updating employee information and making sure everything is compliant with employment laws. Many states also grant employees the right to view their own personnel files. Other roles in your organization may need access from time to time, but that access should be limited to the following:
– Managers might need to look at things like performance reviews, disciplinary actions, or salary history.
– Payroll and benefits administrators will need access to pay and benefit information to handle pay, taxes, and benefits enrollment.
– Legal counsel may need access in the event of legal disputes, compliance audits, or investigations.
No one else should have access or be able to look at employee files. And even for those who do have access, they should only be reviewing the files, or parts of the file, they need to see. Having separate files for certain sensitive information (like medical documentation and I-9s) will help ensure that a manager reviewing a personnel file for performance review scores doesn’t stumble into information about an employee’s disability or other protected characteristics.
Make sure personnel files are stored securely—use locked cabinets for paper files and restrict access for electronic ones.
This Q&A does not constitute legal advice and does not address state or local law.
