Personnel Records Management
1. PURPOSE
As an educational institution supported by The Church of Jesus Christ of Latter-day Saints ("Church"), BYU–Hawaii’s ("university") record-keeping practices are informed by the direction and counsel given to the Church in Doctrine and Covenants 47:1-3 and 85:1 regarding the importance of maintaining an accurate history of “all things that transpire in Zion.” In addition, business necessity, federal and state statutes, and a need for prudent anticipation of litigation risk dictate specific obligations with respect to the creation, maintenance, and disposition of employment records. In order to satisfy these responsibilities, the university has adopted this Personnel Records Management policy, the purposes of which are: a) to establish accountability for the management of employment records, b) to create safeguards against unauthorized or accidental disclosure of confidential records, c) to define the time frame for personnel records retention, and d) to provide for appropriate disposal practices.
BYU–Hawaii is committed to a policy of compliance with applicable law and adoption of best practices regarding the creation, maintenance, use, and retention of information about university employees – from initial application to separation. This policy also includes a commitment to protect the privacy of employees’ personal information collected to serve the university’s obligations as an employer.
2. POLICY
CONTENTS OF PERSONNEL RECORDS
The director of Human Resources must ensure that only job-related information is collected and retained in the personnel file and that restricted access items are segregated from general information items.
Personal information
The university collects and retains personal information (name, address, phone number, SSN, date of birth, etc.) solely for the purpose of discharging its responsibilities as an employer, will not use the information for any other purpose, and accepts the responsibility to safeguard this information from unauthorized disclosure.
General information items
General information items include personnel records used in making hiring, compensation, promotion, and career development decisions. The general information section of the personnel file includes, but is not limited to, the following categories of personnel records:
| Acceptance letter | Licenses |
| Application (signed upon hire) | Non-medical test results |
| Awards, certifications, achievements | Offer letters |
| Compensation information | Orientation checklists |
| Disciplinary actions issued(e.g., verbal or written reprimand, suspension, termination) | Performance evaluations |
| Ecclesiastical endorsements | Personnel action forms |
| Education reimbursements | Policy acknowledgments |
| Emergency contact forms | Position description |
| Employee incident reports | Promotion actions |
| Equipment, keys, tools, etc. acknowledgments | Requests for corrective action |
| Examples of work | Requests to review file |
| Exit interview questions | Resume |
| File access log | Salary change approvals |
| Honor code acknowledgments | Salary history |
| Improvement plans | Terminations |
| Job description questionnaire | Training records |
| Leave forms (not medically or FML related) | Transcripts |
| Letter of resignation | Transfer actions |
| Letters of commendation or letters of complaint |
Restricted Access
Federal law and the university’s commitment to respect employee privacy require that some items of information, required for administration of benefits programs and other employer obligations, be subject to restricted access. Accordingly, the following types of records are to be maintained in a separate section of the Personnel File with, unless otherwise required by law, access limited to records custodians, responsible university officials, and the employee:
| ADA accommodation requests | Health, Dental, Vision, Pharmacy plan enrollment records |
| Alcohol and drug testing reports | Injury reports |
| Background investigations | I-9 verification forms |
| Beneficiary designations | Interview evaluation forms and reference checks |
| Benefit plan choices and beneficiary information | Investigatory notes and attorney-client communications |
| Challenges to the accuracy of items included in the personnel file | IRA/401k elections |
| COBRA acknowledgments | Legal actions including harassment and discrimination complaints |
| COBRA notices | Medical information |
| Deduction authorizations | Other insurance enrollment forms |
| Dependent information | Payroll deductions |
| Direct deposit forms | Physical exam reports |
| Disability claim forms | Promotion and Tenure records |
| Discrimination complaints/investigations | Provider certifications |
| Employment/payroll verification requests | Reasonable accommodation requests (ADA) |
| Expense reports | Reasonable suspicion drug/alcohol test results |
| FMLA requests | Timesheets |
| FMLA return to work certifications | Voluntary disclosures |
| Garnishments | W-4 |
| Genetic information | Worker’s compensation claims |
| Grievances |
DEFINITIONS
Personnel File – The official collection of personnel records in the custody of the university’s Human Resources department which is used or has been used to determine an employee's qualifications for hiring, promotion, compensation, termination, or disciplinary action for the administration of employee benefits programs; or for meeting the university’s other employer obligations.
Supervisory Notes – Records, not included in the personnel file, kept by supervisors and used to document observed work performance and behavior. All documents in this file are to be dated and contain factual, not subjective information. While not part of the personnel file, these items may be used to document observed work performance and behavior and may include informal notes to be used in future discussions regarding an employee’s job performance. Supervisors must be consistent and equitable in record keeping.
Personnel Record – A hard copy, computer file, audio file, photographic file, or document in any other format containing information that relates to a person’s employment at the university.
Records Custodian – The director of Human Resources and staff of that office designated to maintain personnel files. Employees whose jobs involve the handling of personnel records are obligated to strictly observe the stipulations of this policy and never use confidential information about other employees for their own personal advantage.
Responsible University Official – The director of Human Resources, the Title IX coordinator, or any other university executive expressly assigned to oversee the resolution of a grievance, claim of harassment or discrimination, or other extraordinary matter not incident to normal hiring, compensation, promotion, and career development decisions.
4. IMPLEMENTATION