Detailed personnel files management is beyond the scope of this article. Suffice to say that employers should consider taking the following steps, with awareness of certain “hot button” issues where records retained encompass medical information, EEO compliance, immigration and other “confidential” files:

Step 1: Establish a policy for personnel files.

Step 2: Establish a system for purging the files are the required retention period.

Step 3: Establish separate “Confidential” files for:

• Medical records
  
• Equal Employment Opportunity records.
  
• I-9 Files (Immigration and Naturalization—all I-9s should be kept in one common file rather than individual employee files)
  
• Other “Confidential” files such as investigative files for harassment, discrimination claims, and background and reference checks.
  
  

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