From the Hotline: Personnel Files and Benefit Documents

Question: May benefit enrollment documents be placed in the employee’s personnel files or should they be kept separate?

Answer: Due to privacy concerns, it is considered a best practice to keep all benefit documents in a separate file and location from personnel records. Confidential information is contained within benefit enrollment forms, including dependent information that require a high level of security.

We recommend keeping separate files as such:

  • Personnel file – employment application, resume, job description, offer letter, reference checks, status change forms, acknowledgement of company handbook and policies, verification of employment requests, address change forms
  • Payroll file – compensation changes, W-4 and state tax withholding forms, direct deposit forms
  • Benefits file – enrollment/waiver forms, enrollment change forms, medical forms
  • Wage Garnishment file- as needed, should be separate from personnel and payroll files
  • FMLA file and/or ADA file – as needed, should be separate from personnel, payroll and benefits files
  • I-9 forms – should be kept separate from other employee files.  Employers may keep all active I-9 forms in a binder, and all terminated I-9 forms in a separate binder.