Good Practice and Information Guidance
No. 7
Managing HR information in departments

Why do departments have HR information?

This guidance is to provide a source of reference for you to manage your records more effectively. The primary responsibility to manage employee information is with Human Resources (HR) but for some activities and processes e.g. Performance & Development Review, departments are required to create and manage information.

• We need to keep information to meet both statutory obligations and internal administration. Information about individuals is necessarily kept in HR and at a local level (in departments, SEPS, UHS etc) to meet our responsibilities as employers.
• Access to information about individuals is covered by a range of legislation, which includes: the Data Protection Act 1998, the Race Relations Act 1976 and the RRAA Race Relations (Amendment) Act 2000, Employment Act 2002 and Employment Tribunals regulations.
• Special care should be taken to ensure that all records are appropriate in tone and content and accurate. You should only retain “file notes” whilst they are relevant.  Remember that the person who is the subject of your comments has a right to be given access to them through the Data Protection Act 1998!

When staff collect or share personal data they should ask themselves whether the information collected is:

• Adequate and relevant (i.e. not excessive) for the purpose which it is has been collected?
• Its use communicated clearly to the member of staff (both pro-actively and when they ask)?
• Retained for an appropriate period of time (e.g. until the purpose stated is completed)

Staff should be made aware:-

• Of the purpose for which these records will be kept,
• Of the use that such information may be put to,
• Of the retention of such information on their file and
• By whom such information may be accessed and with whom any information contained in their file may be disclosed / shared.  

There is a detailed records retention schedule for HR information held in departments. In addition the University has an approved Staff Exit Procedure to be followed when staff leave the University.  

Responses to changes in status

Q.1 In the event of staff leaving the University to go to a new job how long should a line manager keep hold of any personal data they have on that individual?  e.g. performance review notes, personal development  planning notes etc.

Once a member of staff leaves, the main purpose of retaining the local staff file is so that reasonable detailed references can be written in the short term, so the main types of information which should be retained on the file relate to "career progress".

The departmental files should certainly not be retained longer than 6 yrs from the date of leaving but in practice it is unlikely that you will need to refer to detailed records more than 1 year after the date of leaving. Core staff information (dates of service, posts held etc) can be provided by the HR system.

Departmental records reduce rapidly in value over time so it is advisable to destroy them within 1 year of the date of leaving. In order to be compliant with the Data Protection Act 1998 ex-employee files should be weeded as soon as practical (preferably within 6 months) once the individual has left the University. Care should be taken to dispose of "sensitive personal data" as defined by the Data Protection Act on a regular basis. A list of these is given on this web page:

http://www.gla.ac.uk/services/information/atoz/sensitivepersonaldata.html

In effect this means that all records relating to the following topics should be removed once an individual leaves:

• Copies of personal information sent to HoDs (e.g. financial or welfare issues)
• Financial information (e.g. relating to salary changes)
• Anything relating to unacceptable conduct (e.g. misuse of IT facilities, disciplinary proceedings).

Information about health (e.g. medical certificates, letters from medical practitioners or welfare services or information from the Occupational Health Unit) should only be retained for the current tax year plus 3 years from date of creation. So information verifying absence through illness may need to be retained after the individual has left in case of queries by HMRC.

The central HR record is weeded approximately 6 months after the member of staff leaves the University to remove time-expired and redundant information, for example, an employee's basic personal details (e.g. home address, next of kin, emergency contacts). For staff who left after 1980 the basic employment profile can be retrieved from the online database so detailed staff information is fully disposed of 6 years after the person leaves the University.

There is a detailed records retention schedule for HR information held in departments. In addition the University has an approved Staff Exit Procedure to be followed when staff leave the University.  

Q.2 If a department is merged with another and some staff end up with a change of line management as a result of re-structuring what kind of information should be passed onto a new line manager and what shouldn't be passed on?

In addition to routine file maintenance, the best guide for responding to this question is to assess what types of information will be relevant to the new post. So if your routine file maintenance is up to date only a fairly limited range of records need to be transferred to the new line manager.

Therefore do not pass on time expired or redundant information (as outlined above).  Be especially conscious of any “file notes” that have been added to the file.