Safe to say that employees are your company’s prime asset? So are their data. Your company needs employee data to perform the simplest of tasks. There is no deciding which candidate to hire without resume’s and interview notes. No paying any salaries without bank account details, right? No sending any email without a name and email address. No functioning of your core CRM system without log data. To ensure your company has these data when it is to make sound HR decisions, employee data retention is key.
Your company needs employee data to survive. Your company also needs to delete employee data: to prevent having, to limit discovery spend & risks and to comply with the GDPR. Your company should strike exactly the right balance between keeping and destroying as employee data should be deleted when data is ‘no longer necessary’.
Maybe legal incentives are not even most important: happy employees give your companies wings. Employees are more and more aware of the value of their data, and their privacy rights. Protecting and treating their data well strengthen employees’ trust and motivation. On the flipside, distrustful, critical employees can cause serious headwind. If a deleted bank account number prevents them from receiving their salaries in time they will lose their spirit. Getting in control of employee data retention and communicating well to your employees about how long HR data will be stored is vital to build trust.
The secret to the art of employee data retention? It is all in the data categories. Implementing all individual retention periods for each country your company is active is difficult, time consuming and costly. An extra burden your business can live without. Divide all employee data available in your company into data categories. This will allow you to get in control of employee data retention both effectively and efficiently.
Choose your data categories wisely
- Candidate data
This employee data category includes all information your company collects during the hiring process. Examples include: application letters, CVs, references, certificates of good conduct, job interview notes, assessment results and psychological test results.
- General personnel data
The general personnel data category exists of the general part of the HR or personnel file with identification and contact details of the employee. This data category would include: name, date of birth, sex, nationality, full home address, tax registration number, work email address, private email address, work telephone number, private telephone number, racial or ethnic origin, emergency contact details and any unique national, state, provincial, or local identifier (e.g., passport, tax ID number, US social security number, Canadian social insurance number or license numbers)
- Identification documents
Identification documents such as copies of passport, national ID card, driver’s license would be regarded as a separate data category. Each country has specific rules and legislation on how these documents should be handled and retained. Considering these a separate data category from general personnel data facilitates the implementation of per country differences.
- Employment data
This HR data category includes all information relating to the employment and employment contract of an employee. Examples include: employee contract details, employment terms and conditions such as pay, hours of work, holidays, benefits, date of hire, current and previous position titles, current and previous job descriptions, which department or team the employee is working in, full-time, part-time or other employment status, membership of works council or employee representative body.
- Payment data
Payment data would include all financial data relating to an employee required to pay his or her salary or employment. This employee data category includes salary information and payslips, tax information, social security records, overtime compensation, bonuses, expenses, bank account numbers, debit card number, credit card number, credit reports, credit scores and fraud alerts, loan records and balances, remuneration history, emolument details, pension data, employee stock and options records and disbursements.
- Absence, sickness and health data
This date category exists of all absence, sickness and health related information on your company’s employees. Examples include clocked hours or worked hours (in case of individualized hours or individually recorded hours or time records), sick days, leave data (holiday and any absence other than sickness), physical characteristics (height, weight, hair colour, skin tone, tattoos and piercings), any accidents connected with work, disability information, genetic Information, physical or mental health information, blood type, personal health insurance information, information on drug tests, data relating to an employee’s health care provider, health plan.
- Performance data
The performance data category includes all data relating to education and the functioning of an employee within a team, department or company. This includes performance reviews, test scores. disciplinary actions. information relating to litigations, ediscovery proceedings, subpoenas, internal investigations, regulatory investigations and other contentious legal cases (including settlements) involving the employee.
- Work documents
The work documents category includes all emails, documents, power points, excels, notes etcetera prepared by an employee. Don’t forget about the employee’s personal folder on your company’s server.
- Account and technical data
The data part of the account and technical data category will sound very familiar to your IT department. Examples include: user name, password, video programming activity information, device identifiers (such as serial numbers, MAC-addresses mobile phone UDIDs), URLs (Web Universil Resource Locator), internet Protocol (IP) address, communications meta-data, log data and any other identifier that permits the physical or online contacting of a specific individual (e.g., user ID).
- Severance pay records
This severance pay records data category exists of the information related to the termination of an employee contract. This includes notification to and consent of the competent authorities regarding dismissal, decisions of the court regarding dismissal, correspondence with the competent authorities regarding dismissal, outplacement records, calculations of termination payments, a file prepared in relation to the termination of employment and any communications with the employee and other stakeholders.
So, now you have all the ammunition you need to decide which data categories to use in your company. Once you have categorized the employee data present within your company you will be ready to get your employee data retention project on the road. In our next blog, we will discuss how to choose a retention period for each data category. This will allow you to truly master the art of employee data retention and its successful implementation.