Good Practice and Information Guidance
Managing HR Information in Departments
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.
Why do departments hold HR information?
- We need to keep information to meet both statutory obligations and internal administration needs. Information about individuals is necessarily kept in HR and at a local level (in departments, SEPS, UHS etc) in order meet our responsibilities as employers.
- Access to information about individuals is covered by a range of legislation, including the General Data Protection Regulation, 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 accurate and appropriate in tone and content. You should only retain file notes for as long as 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 General Data Protection Regulation.
When staff collect or share personal data they should ask themselves whether:
- That information is adequate and relevant (i.e. not excessive) for the purpose which it is has been collected
- Use of that information was communicated clearly to the relevant member of staff (both proactively and in response to enquiry)
- That information is 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,
- By whom such information may be accessed, and
- With whom any information contained in their file may be disclosed or shared.
In addition the University has an established procedure for staff leavers, to be followed when University employment terminates.
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.)?
A.1 Once a member of staff leaves, the main purpose for retaining the local staff file is to assist in providing detailed references. The types of information which should be retained on the file relate to "career progress". Core staff information (dates of service, posts held etc) can be provided by the HR system.
Departmental records reduce in value rapidly over time, so it is advisable to destroy them within 1 year of the date of leaving. To ensure compliance with the General Data Protection Regulation, ex-employee files should be weeded as soon as practical (preferably within 6 months) after the individual has left the University. Care should be taken to dispose of special category personal data,as defined by the General Data Protection Regulation (GDPR), on a regular basis. 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. 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, including an employee's basic personal details. 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.
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?
A.2 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. If your routine file maintenance is up to date, only a limited range of records need to be transferred to the new line manager.
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.
For further advice on managing HR records within your department, please contact the:
Records & Information Management Service
tel: +44 (0)141 330 6494 or 5146