The Employment File
There is no single file. There are seven, held by different people under different assumptions, and the request treats them as one.
WHERE THE FILE ACTUALLY IS
Map it once. Most employers find seven locations
- HR systemContract, pay, absence, formal recordsThe one everybody thinks of
- Manager folderNotes, drafts, one-to-one recordsPersonal drive, usually. The one that surprises
- EmailEverything discussed about them, anywhereThe largest holding by volume
- Payroll providerPay, tax, bank detailsA processor, with its own retention
- Benefits providersPension, insurance, occupational healthSeveral controllers, not processors
- Shared drivesAppraisal forms, team documents, rotasNo owner and no retention
- MessagingConversations about them between managersFrequently forgotten entirely
- PaperSigned documents, old files in a cupboardStill exists more often than expected
A subject access request asks for personal data. The organisation thinks of the HR system and sends what is in it, which is typically a minority of what it holds.
The record described in “The Employment File” should remain evidence of a workflow rather than a shortcut to judging a person. When an employer evaluates this practical implementation page for 7 minute rule payroll, it should define what managers may see, how an employee can correct an inaccurate entry and which decisions require corroboration beyond activity data.
Mapping it once
An afternoon, with somebody from HR, somebody from IT and a manager.
For a separate benchmark relevant to “The Employment File”, consult the BleepingComputer security coverage. Use it to test purpose, data flow, retention, access and response procedures rather than substituting a generic checklist for the organisation’s actual records.
List every place something about an employee could be. Most organisations find seven and are surprised by three of them.
That map serves three purposes at once: the record of processing, the retention schedule, and the search list for every future request.
The manager folder
The holding that causes the most difficulty.
Notes from one-to-ones, drafts of appraisals, a document recording a conversation about somebody's performance, an email thread forwarded to a personal folder.
All of it is personal data, all of it is disclosable, and none of it is in any system anybody manages. Its own note covers what managers should be told.
By volume, the largest holding about any employee, and the one searches most often skip.
Not only their mailbox: messages about them in colleagues' and managers' mailboxes. A search of the person's own mail finds what they sent and almost nothing of what was said.
Benefits providers, who are usually controllers
Pension schemes, insurers and occupational health providers frequently determine their own purposes and are controllers rather than processors.
Which changes what the employer is answerable for and what it must disclose about them. Treating a pension administrator as a processor in the record of processing is a common and visible error.
The practical consequence
A response assembled from the HR system alone is incomplete, and incompleteness is what produces escalation.
The map is what makes a complete response possible in a week rather than a scramble in the fourth.
Keeping it current
A line in the process for introducing any new system: does this hold data about staff, and where does it go on the map.
Without that, the map is accurate on the day it is made and degrades from then on.
Keeping the map current
A line in the process for introducing any system: does this hold data about staff, and where does it go on the map. Without it the map is accurate on the day it is made and degrades from then on.
Benefits providers, usually controllers
Pension administrators and insurers determine their own purposes. Listing them as processors in the record is a common and visible error, and it misdescribes who answers a request about them.
Email is the largest holding
Not only their mailbox: messages about them in other people's. A search of the person's own mail finds what they sent and almost nothing of what was said.
Mapping it once, properly
An afternoon with HR, IT and a manager. The map serves the record of processing, the retention schedule and every future search at the same time.
Paper, which still exists
Signed contracts, old files in a cupboard, a folder somebody kept. More often than expected, and entirely outside every system-based retention arrangement.
Why the HR system is a minority
It holds the formal record. Email, manager folders, shared drives and messaging hold more by volume, and a response assembled from the system alone is incomplete by construction.