From the Hotline: Best Practices for HR File Administration

Question: We have several locations and staff hiring and onboarding is done on site at each location. We currently keep the original personnel file at the location with a faxed copy of each new hire document sent to our main office. In a recent audit, we discovered discrepancies in the I-9 and W-4 paperwork that need to be corrected, causing us to wonder if the original documents should be kept at the main corporate office. What is the best practice for HR file administration?

Answer: Best practice is to retain all personnel files in the corporate location with original documents and provide the working supervisor files in each of your locations. A working supervisor file contains emergency contact, copy of discipline and performance reviews, and training certificates, as well as personal contact information.

If you have found that the Form I-9 is not on file for a current employee, then you should request that the employee complete section 1 of the current Form I-9 immediately and submit documentation as required in Section 2. The new form should be dated when completed — never post-dated. If the documentation on the employee’s Form I-9 is incorrect or incomplete, then you and the employee should use the existing Form I-9 and make corrections near the incorrect or incomplete space. If using paper copies, use a different color pen to note the change. You and the employee may draw a line through inaccurate information, write the correct information on Form I-9, and initial and date the correction. You should also make a note in the file that a self-audit was completed on that date. Make sure that the signature relates to the attestation (“I attest, under penalty of perjury …”). If your company is audited, the examiners will want to have proof that you exhibited a good faith effort to audit your records and correct deficiencies.

Employees can submit W-4 documents at any time. If your audit uncovers missing or incomplete W-4 forms, note that in the file and ask the employee to submit a new form.