As a HR and Payroll Software supplier, Carval often gets asked by new clients "How much data should I transfer from my old HR system?". There is no straightforward answer to this.
In the UK a complex regulatory regime governs the length of time for which HR records should be stored. How long they should be kept - and when they should be destroyed too. Here we look at some considerations.
What constitutes an HR record?
HR records include a wide range of data relating to individuals working in an organisation, for example, pay or absence levels, hours worked and trade union agreements. This information may be stored in a variety of media such as paper files and on HR software.
There are some areas which are covered by specific regulations, for example:
- accident books, accident records/reports
- accounting records
- income tax and NI returns, income tax records and correspondence with HMRC
- medical records and details of biological tests under the Control of Lead at Work Regulations
- medical records as specified by the Control of Substances Hazardous to Health Regulations (COSHH)
- medical records under the Control of Asbestos at Work Regulations
- medical records containing details of employees exposed to asbestos
- medical examination certificates
- medical records under the Ionising Radiations Regulations 1999
- records of tests and examinations of control systems and protective equipment under the Control of Substances Hazardous to Health Regulations (COSHH)
- records relating to children and young adults
- retirement benefits schemes – records of notifiable events, for example, relating to incapacity
- statutory maternity pay records, calculations, certificates (Mat B1s) or other medical evidence
- wage/salary records (also overtime, bonuses, expenses)
- national minimum wage records
- records relating to working time
There are also guidelines and recommendations for a host of other types of employee-related data, including:
- actuarial valuation reports
- application forms and interview notes (for unsuccessful candidates)
- assessments under health and safety regulations and records of consultations with safety representatives and committees
- Inland Revenue/HMRC approvals
- money purchase details
- parental leave
- pension scheme investment policies
- pensioners' records
- personnel files and training records (including disciplinary records and working time records)
- redundancy details, calculations of payments, refunds, notification to the Secretary of State
- senior executives' records (that is, those on a senior management team or their equivalents)
- Statutory Sick Pay records, calculations, certificates, self-certificates
- time cards
- trade union agreements
- trust deeds and rules
- trustees' minute books
- works council minutes
Storing and accessing HR records
It is important for all organisations to maintain effective systems for storing HR data, both to ensure compliance with all relevant legislation (for example in respect of the minimum wage or working time regulations) as well as to support sound personnel administration and broader HR strategy.
Retaining data may address the fundamentals of regulatory compliance, but it will be accessing it that will ultimately prove the challenge. Indeed, it is the ability to access and report on HR data that is often a fundamental driver in organisation's decision to implement HR software.
But what of the historical data that you already have? If your organisation has a lot of records in spreadsheets or in disparate system then converting and importing it into your HR software should be possible. This will enable you to report on historical data much more easily if required to do so.
If your records are largely paper-based then you have, broadly speaking, two options available to you:
1) Continue to physically store the historic data and then move forwards with electronic records.
2) Convert those records into soft copy and make them accessible using a document management system and/or the in-built capabilities in your HR software.
Both have cost and time implications.
Routines for retaining and deleting HR data
It is important to remember that, as the data controller, ultimately the responsibility for keeping adequate records to comply with regulations lies with you.
HR systems and Payroll software have tools to help you, but will usually avoid deleting any data automatically. It is up to you to develop a document retention policy and to adhere to it.
For example Carval's HR Unity has the following features:
An Event Diary and Report Scheduler to flag where certain information is due to expire, for example Qualifications, DBS and Contracts.
Employee Performance Management - looks at the lapse date against the employee disciplinary and enables you to purge lapsed disciplinary records.
Recruitment - the functionality to remove all applicants for a vacancy from the database with the exception of those short-listed applicants whose 'Retain Details' box is ticked on the 'Successful Applicant' screen. This also marks the Vacancy as completed.
Time & Attendance - the ability to archive copies of historical clocking transaction details.
Payroll - the ability to archive pay records for previous periods whilst still retaining them until the purge function is activated via the HR Administrator function. (Note that these records would need to be kept in order for employees to see historical payslips in self-service.)
Backups - advised during key process such as Holiday Year End or Spinal Column Point Uplifts and as such these can be used as archive databases to refer to previous entitlements for leave and annual salary via Test systems.