Employment records

Map each record to a purpose

Employment records cover the information gathered from recruitment through to leaving. They can include contact details, offers and contracts, payroll and pension data, working time, absence, training, performance notes, disciplinary or grievance material and leaver records.

Each category needs a clear reason for being kept. The ICO's employment-record guidance says employers should identify the purpose and lawful basis, collect only what is needed and tell workers how their information will be used. Different categories may rely on different lawful bases. Consent is rarely a safe default in employment because the balance of power can prevent a genuinely free choice.

Keep access narrow and facts clear

Access should follow the job someone needs to do, not their seniority alone. Health, equality and criminal-offence information usually needs tighter controls than an ordinary contact record. Managers should see what they need to manage a person, while payroll or HR owners may need different fields.

Write factual records carefully. Separate an observation from an opinion, identify the author and date, and record a worker's disagreement where it is relevant. Correct inaccurate information rather than letting an old spreadsheet, email and HR record each tell a different story.

Make records findable, reviewable and disposable

A record is still part of your employment information when it sits in a manager's mailbox, local folder, chat export or supplier system. Keep important material in an agreed location so it can be found for a subject access request, reviewed when circumstances change and protected consistently.

Set retention by category and purpose rather than applying one lifetime to the whole personnel file. At the end of the justified period, delete the information securely or anonymise it properly. Your privacy information should explain what you keep, why, the legal basis, recipients, retention and the route for exercising rights.