Managing recruitment and personnel records

Types of personnel records

Personnel records cover a wide range of information, including:

• Employee-specific records: Individual files detailing employment history, service, and separation, often called personnel or employee files.
• Non-employee-specific files: Organised by activity or topic, such as procedural files, recruitment records, or policy documentation.
• Data in management systems: Information stored in systems like talent management, recruitment, payroll, or performance management platforms.
• Attendance and leave records: Often managed within business applications, for example, SAP systems.

Regulatory and organisational considerations

It’s important to understand the regulatory framework for personnel records, as these requirements need to be incorporated into the design of recordkeeping systems for personnel records, and policy and procedures for managing records.

The following should be considered in managing personnel records:

• retention periods for personnel records are specified in General retention and disposal authority: administrative records (GA28), General retention and disposal authority: local government records (GA450)
• Privacy and Persona­­­­l Information Protection Act 1998 (PPIP Act)
• Government Information (Public Access) Act 2009 (GIPA Act)
• Health Records and Information Privacy Act 2002 (HRIP Act)
• Government Sector Employment Act 2013 and associated guidelines (see also Government Sector Employment Regulation 2014)
• Long Service Corporation Act 2010 No 123
• Long Service Leave Act 1955 No 38
• awards or enterprise agreements which identify salaries, wages and conditions of employment, e.g. enterprise agreements of universities establish rules, conditions and entitlements of employees
• policies and procedures from the NSW Public Service Commission
• policies and procedures for access/privacy/security
• as personnel records contain sensitive personal and health information, they must be handled with care and in line with the NSW Government Information Classification, Labelling and Handling Guidelines
• organisational policies and procedures.

Personnel summary records

If you are holding legacy records such as hard copy staff cards which summarise a person’s employment, these are required as State archives under the General retention and disposal authority: administrative records (GA28 15.4.1).

For an example of a hard copy staff card see Employee History Cards from the Public Service Board from 1911-1968 held in the State Archives Collection.

If you have a business need to create a summary record of employee history, including from electronic recordkeeping systems, then these are also required as State archives under GA28, 15.4.1, provided that they include employee’s name, date of birth, dates of employment/service, positions held and salary, and locations worked.

Please note that:

• State Records NSW does not require summary records to be created.
• A summary record is not a service file. A summary record contains metadata about the employee but not documents.

Employee service history records/files

Previously referred to as “P” files but with the advent of electronic employee systems such as SAP, a separate discrete file for an employee may no longer be created. Employment service histories are required to be retained for a minimum 75 years after date of birth of employee or 7 years after employment ceases, whichever is longer.

They cover the appointment and subsequent employment history, including separation. These records could include:

• job applications and resumes
• results of conduct and services checks
• letters of appointment and acceptance
• recognition of prior service
• confidentiality agreement as part of employment
• code of conduct
• service records
• training for occupational health and safety or other training required as part of employment conditions to perform their duties
• correspondence, reports etc relating to separation.

The following records should not be placed on the employee service history files as they are not required to be retained for 75 years after date of birth:

• flex sheets
• workplace agreements
• secondments or transfers
• grievance records
• staff performance management
• conflict of interest
• detailed records of various conduct checks
• applications of leave
• criminal records checks.

These personnel records have a shorter retention period (e.g. minimum 7 years after action) and can be sentenced under GA28 15.0.0.

Note:

• employees that leave the organisation are still required to have their records migrated (during system migrations) and accessible for the required retention period as past employees may still require access.
• contractor or volunteer service history records are only required to be retained for a minimum of 7 years after service completed or until person reaches age of 25, whichever is longer under GA28 15.4.4.
• records documenting the selection and appointment of chief executive officers, statutory officers appointed by the Minister (such as Chief Justices, Registrar-General, Surveyor-General, judges, magistrates, Director of Public Prosecutions), University Chancellors and Vice Chancellors are required as State archives under GA28 15.4.2. Noting that the subsequent employment service histories are still to be retained for 75 years after date of birth.

Recruitment records

It's important for agencies to keep full, accurate, and reliable records of recruitment processes for several reasons, including:

• dealing with appeals against recruitment decisions
• assisting employees in confirming their rights and entitlements
• managing the details of applicants held in 'reserve' through eligibility lists
• managing historic Workers Compensation matters

Agencies need to make informed, risk-based decisions about how to manage different recruitment records. This includes deciding which records can be kept in e-recruitment systems and which ones should be transferred to the agency's own recordkeeping system. The rules for retaining and disposing of recruitment records, are outlined in the General Retention and Disposal Authority for Administrative Records (GA28 15.9.0).

Most e-recruitment systems do not fully meet the requirements of the State Records NSW’s Standard on records management. However, they may include some basic recordkeeping features, such as the ability to capture read-only records, provide security and track audit trails.

For most recruitment processes, these basic features are enough to manage short-term records. Generally, short-term records only need to be kept for 2 years after the recruitment is finalised. If your agency has concerns about the risks to these records, it should consider alternative methods for storing them, such as exporting them to the agency's own recordkeeping system.

E-recruitment systems are not suitable for maintaining records with long-term retention requirements. Records of successful candidates, which are needed for ongoing management of their appointment and service, must be exported from the system and stored in the agency's own records management system. This export should take place once the candidate is notified.

Contractor / Volunteer employment records

Employment records of contractors or volunteers are to be retained for a minimum of 7 years after service completed or until person reaches age of 25, whichever is longer.

Contractor or volunteer appointment and service records are retained for a shorter retention period than casual/permanent staff and include:

• volunteers
• individuals on work experience placements and job assistance schemes
• individuals employed on a short-term or casual basis where the terms of engagement do not provide for the accrual of on-going rights and entitlements
• individuals employed for one-off or short-term recurring events such as open days
• person’s or individuals engaged to provide particular services on an ‘as required’ basis.

Note:

• If a contractor or volunteer becomes a full-time employee, their original service history is still retained for the 7 years after service completed and they will have a new employment record created under the new contract.

• For contingent employees from external employment agencies, the public agency may not hold the employment records as they are managed through their employer (the employment agency). 

   

Management and ownership of records in shared services environment

Personnel files have a long retention period (75 years after date of birth) and must be managed and controlled under the State Records Act.

See the table below for who retains the responsibility of employment service history records: