CIPP/E Study Guide
Ch 14.5 - Personnel records

Storage of personnel records

Personnel records span recruitment, sick leave, medical insurance, salary, appraisals, evaluations and severance. They must not be kept longer than necessary. While someone is a current employee there is a legitimate reason to retain their data; once they leave, that reason diminishes. Some local laws (company, employment, health and safety, tax, social security) require retention for set periods.

Retention logic across the employment lifecycle
StageRetention position
Current employeeEmployer has a legitimate reason to retain the data
After employment endsReasons to retain diminish; change internal access to the records
Statutory retentionCompany, employment, health & safety, tax and social security law may require retention
No longer neededData that must be kept should be securely archived with restricted access
After someone leaves

There is unlikely to be a day-to-day HR need to access former-employee records, so change internal access and securely archive the data that must be retained.

Key terms - quick answers

What is “Storage limitation”?
The principle that personal data must not be retained for longer than necessary for the purposes processed.
What is “Secure archiving”?
Restricting access to a former employee's records and storing them securely once daily HR access is no longer needed.