What Managers Keep in Their Own Notes
The largest unmanaged holding in any organisation, written by people who believe it is private, and fully disclosable.
NOTE THAT WILL BE READ
Guidance for managers, on one page
- WhereIn the HR system where possible, not a personal drivePersonal folders are still in scope
- What it isPersonal data about the personNot a private aide-memoire, whatever it feels like
- DisclosableYes, to them, on requestIncluding rough notes and drafts
- WriteConduct and observations, datedWhat was said and done
- Do not writeConclusions about character, speculation, health guessesThe three that appear in tribunals
- OpinionsPermitted, and must be defensibleAn opinion you would state to their face
- RetentionSame as the record it relates toNot kept indefinitely because nobody deletes a folder
- At exitTransferred or deleted, not inherited silentlyA new manager reading old notes is a separate problem
A manager keeps notes: a one-to-one summary, an observation about performance, a record of a conversation that might matter later.
The record described in “What Managers Keep in Their Own Notes” should remain evidence of a workflow rather than a shortcut to judging a person. When an employer evaluates this workplace technology guide for employee monitoring data security, it should define what managers may see, how an employee can correct an inaccurate entry and which decisions require corroboration beyond activity data.
They believe these are personal working papers. They are personal data about the employee, held by the organisation, and fully within scope of a request.
For a separate benchmark relevant to “What Managers Keep in Their Own Notes”, consult the SCCE compliance resources. Use it to test purpose, data flow, retention, access and response procedures rather than substituting a generic checklist for the organisation’s actual records.
Why managers do not know
Nobody has told them.
The induction covers the HR system and the policies. It does not say that the folder on their laptop containing six months of notes about their team is organisational data, discoverable, and likely to be read by the person it describes.
The discovery usually happens during a request, at which point the notes exist and have already been written.
What appears in them
Mostly unremarkable: dates, topics, agreed actions.
And occasionally: speculation about somebody's home circumstances, a guess about their health, a judgement about their attitude, a comment about how they came across — each of which reads very differently in a tribunal bundle than it did on a Tuesday afternoon.
The guidance that works
One page, at induction and annually.
Write what was said and done. Date it. Opinions are permitted and must be ones you would state to the person. Avoid speculation about anything you have not observed, particularly health and personal circumstances.
And keep it where the organisation can find it, because a note that cannot be found cannot be disclosed, and failure to disclose is the organisation's problem rather than the manager's.
The search problem
A request requires reasonable searches, and manager folders are a reasonable place to look.
Which means asking managers to search their own material, which requires them to know what counts, which requires the guidance above. Organisations that have not given it conduct searches that miss the largest holding.
What to do with existing notes
Ask managers to review and move anything that should be in the system.
Expect resistance, because some of what is there was written on the assumption of privacy. That is exactly why the exercise is worth doing before a request arrives rather than during one.
The inheritance problem
A manager leaves and their notes pass to a successor who reads six months of commentary about people they have not yet met.
Deciding deliberately what transfers — the factual record, not the impressions — is a small intervention with a disproportionate effect on how people are treated.
What to tell managers, in one page
Write what was said and done, dated. Opinions are permitted and must be ones you would state to the person. Avoid speculation about anything you have not observed, particularly health and personal circumstances.
Reviewing what already exists
Ask managers to move anything that belongs in the system. Expect resistance, because some of it was written assuming privacy — which is exactly why the exercise belongs before a request rather than during one.
Nobody told them. The induction covers the HR system, not the fact that their folder of notes is organisational data likely to be read by the person it describes.
A request requires reasonable searches and manager folders are a reasonable place. Which requires asking managers to search, which requires them to know what counts.
Where the notes should live
In the system where possible. A note that cannot be found cannot be disclosed, and failure to disclose is the organisation's problem rather than the manager's.