Nonprofit Association of Oregon



Recording Keeping Procedures – Human ResourcesCBO NAME will retain, store and dispose all human resources related documents by the following category of documents. Access to these records will be kept restricted to the authorized CBO NAME positions.Personnel FilesPersonnel files will be created for each employee and volunteer of CBO NAME. The records can be paper or electronic provided there is consistency with the procedure and storage.Personnel files will include all relevant paperwork an employee or volunteer completes upon hire and during the course of their service. Documents will include but not be limited to: applications, offer letters, performance reviews, corrective actions, W4s and documentation of pay changes. Employees have a right to access their personnel record during and after their employment. CBO NAME will ensure that documentation in the personnel file is information the employee is aware of during the course of their employment.Personnel files are to be restricted to only authorized CBO NAME positions that act in administrative capacity. All personnel files will be kept in a locked and secure location with restricted access.Personnel files will be retained for 7 years following the termination date of an employee. Terminated personnel files will be stored with the same security as active files. Following the set time of retention, personnel files will be destroyed by a secure and confidential means such as shredding, incineration or secure deletion if electronic.I-9sCompleted I-9 forms will be retained separately and securely from the personnel files for all employees. If copies were made of the supporting identification documentation from employee, those will be retained with the I-9. All I-9s contain confidential and sensitive information and will be kept in a confidential and secure location under lock.Updated I-9 forms will be stored with the original I-9 form for each employee. In some cases, the I-9s may be required to be shared under contract requirements with designated representatives of external parties such as federal or state authorities. CBO NAME will work to make sure access and review is done securely.I-9 forms will be retained for all terminated employees for either 3 years after the date of hire or 1 year after the termination date, whichever is later. When the retention period has ended, the I-9s will be destroyed by a secure and confidential means such as shredding, incineration or secure deletion if electronic.Background Checks and Drug TestsAll completed background checks and drug test forms and their results will be retained separately from the personnel file for each employee and volunteer. The files will be retained in a confidential and secure manner under lock. Access to the background check and drug tests results are confidential and may only be shared with approved staff or under legal requirements. In some cases, these results may be required to be shared under contract requirements with designated representatives of external parties such as federal or state authorities. CBO NAME will work to make sure access and review is done securely and only relevant information is shared when possible.Background checks and drug tests will be retained for 1 year following the termination date of an employee. Terminated files will be stored with the same security as active files. Following the set time of retention, the files will be destroyed by a secure and confidential means such as shredding, incineration or secure deletion if electronic.Medical Records and Protected Leave DocumentsWhen an employee is required to share confidential medical information for such reasons as protected leave support or reasonable accommodation, CBO NAME will store all such records separately and securely under lock. These documents will always be separate from the personnel file and will not be accessed by any CBO NAME staff who do not have authorization. Authorization will be restricted to high level administrative positions. Information of protected medical information will not be shared with supervisors or other staff, only information relevant to supporting employees in their position (examples include restrictions on work activities, length of time away from work).Medical and protected leave documents will be retained for 1 year following the termination date of an employee. Terminated files will be stored with the same security as active files. Following the set time of retention, the files will be destroyed by a secure and confidential means such as shredding, incineration or secure deletion if electronic.Internal Audit and ReviewCBO NAME will conduct internal yearly audits of the above documents to make sure forms are present, accurate and properly stored. During this audit, CBO NAME will take care of the disposal of all files that are past the retention date.Record Keeping Notes:There are best practice dates of retention for files in Human Resources rather than set federal requirements with the exception of I-9s. Recommend determining a system of retention and disposal that works best for your organization. For files where you are setting the time frame, be sure to account for legal lawsuit considerations following termination. You may also permanently retain files though space and cost is a consideration you’ll want to take into account. ................
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