When asked to audit the employee files of a new client, the client shared that every single piece of paper signed by the employee from their start date to the present would be found in a single manila folder with the employee’s name on the tab. It is good to have the appropriated signed employee paperwork on file, but not all in one folder.

To be compliant and to reasonably protect the personal, private information of each employee, the employer needs to file documents in separate files and a security clearance hierarchy needs to be put in place.

To start, a manila folder can be used to keep the employee’s:

• Job Application
• Resume
• Job Description
• Performance Reviews
• Disciplinary Action Forms
• Vacation/Sick Leave Request Forms

These documents do not have employee Social Security Numbers, Driver’s License Numbers, etc. These documents can be accessed by the employee’s supervisor along with Senior Management and Human Resources.

A separate folder, suggest red, can be used to keep the employee’s medical enrollment forms and other medical information:

• Medical enrollment form
• Dental enrollment form
• Life/LTD enrollment form
• Medical Leave requests
• Other medically related documents
  • Work Comp medical claim forms/info should be a separate sub-folder

This folder should be accessed only by Human Resources and the owner/CEO, if necessary

A separate folder, suggest green, can be used to keep the employee’s payroll info protected:

• Tax forms
• Child Support court order deduction paperwork
• Child Support court order medical deduction paperwork
• Retirement plan enrollment forms
• Timesheets
• Direct Deposit enrollment form
• Other payroll related documents/forms

This folder should be accessed only by Payroll, Human Resources, and the owner/CEO, if necessary.

A separate folder, suggest blue, can be used to keep the employee’s certifications, continuing education support documentation, and/or licenses required:

• Red Cross First Aid and CPR certifications
• Professional certifications and/or continuing education requirements
• Other company required certifications, licenses, continuing education, and/or company required documentation that renews on a regular schedule

These documents can be accessed by the employee’s supervisor along with Senior Management and Human Resources.

Current I-9 Forms need to be in a separate folder, suggest yellow:

• Active Forms
  • Can be kept in a group in alphabetical order

Terminated I-9 Forms need to be in a separate folder, suggest purple:

• Terminated Forms
  • Can be kept in a group in alphabetical order

The I-9 Forms contain personal, private, protected information on employees, and these files need to be kept in a separate drawer from the other files and should only be accessed by Human Resources and the owner/CEO, if necessary.

Employers are expected to protect the personal, private information for all employees and to maintain compliant files. Best Practice for paper files is behind a locked cabinet, behind a locked door. Use the same premise for digital files. Employers are also required to keep employment documents for varying periods of time and then properly shred these documents.

The folder breakdown above is not meant to be all-inclusive but to provide a starting point for how to keep employment documents filed appropriately and providing access to management accordingly with Human Resources as the guardian of all employment documents. Office supply stores sell boxes of colored-folders including red, green, blue, yellow, and purple for easy filing.

Employers should take the time to review their document management before an audit happens and not after the fact. Misfiling of employment documents can be costly if not addressed appropriately.

One manila folder per employee for employment documentation doesn’t cut it any more. What do your employee folders look like?

Questions – Close HR Connections is available for a consultation and/or can audit your files for compliance, so you’ll be ready for any audit down the road.