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Personnel Records Management


As an educational institution supported by The Church of Jesus Christ of Latter-day Saints ("Church"), Brigham Young University–Hawaii ("BYU–Hawaii" or "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.



3.1.1 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.

3.1.2 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.

3.1.3 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.

3.1.4 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.

3.1.5 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.


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.

3.2.1 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.

3.2.2 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 letterLicenses
Application (signed upon hire)Non-medical test results
Awards, certifications, achievementsOffer letters
Compensation informationOrientation checklists
Disciplinary actions issued(e.g., verbal or written reprimand, suspension, termination)Performance evaluations
Ecclesiastical endorsementsPersonnel action forms
Education reimbursementsPolicy acknowledgments
Emergency contact formsPosition description
Employee incident reportsPromotion actions
Equipment, keys, tools, etc. acknowledgmentsRequests for corrective action
Examples of workRequests to review file
Exit interview questionsResume
File access logSalary change approvals
Honor code acknowledgmentsSalary history
Improvement plansTerminations
Job description questionnaireTraining records
Leave forms (not medically or FML related)Transcripts
Letter of resignationTransfer actions
Letters of commendation or letters of complaint

3.2.3 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 requestsHealth, Dental, Vision, Pharmacy plan enrollment records
Alcohol and drug testing reportsInjury reports
Background investigationsI-9 verification forms
Beneficiary designationsInterview evaluation forms and reference checks
Benefit plan choices and beneficiary informationInvestigatory notes and attorney-client communications
Challenges to the accuracy of items included in the personnel fileIRA/401k elections
COBRA acknowledgmentsLegal actions including harassment and discrimination complaints
COBRA noticesMedical information
Deduction authorizationsOther insurance enrollment forms
Dependent informationPayroll deductions
Direct deposit formsPhysical exam reports
Disability claim formsPromotion and Tenure records
Discrimination complaints/investigationsProvider certifications
Employment/payroll verification requestsReasonable accommodation requests (ADA)
Expense reportsReasonable suspicion drug/alcohol test results
FMLA requestsTimesheets
FMLA return to work certificationsVoluntary disclosures
Genetic informationWorker’s compensation claims



Policy Owner: Human Resources Director

Executive Sponsor: Administrative Vice President

Approved by President’s Council: 06/13/2016

Modified: 12/10/2019

Full revision history maintained by the Office of Compliance & Ethics.