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Human Resources Records Retention Policy

Purpose

The purpose of this policy is to provide information related to how the Human Resources Department (HR) retains and destroys employment records. It outlines how long documents and information are stored, whether in hard copy or electronically, before it is destroyed.

Maintenance of Emplooyee Records

HR maintains several types of employment records on applicants and employees. Depending on the type of information contained in the record, HR may maintain multiple, separate employment files. These include:
  1. Pre-employment testing results and background check information.
  2. I-9 forms.
  3. Benefits plan and employee medical records.
  4. Health and safety records.
  5. General employee personnel records.
Government compliance reports are maintained in reverse chronological sequence and filed separately from the above employee information records.

Destruction of Employee and Applicant Records

Personnel records include electronic as well as paper records. All paper personnel records and confidential employee data maintained by the HR department will be destroyed by shredding after retention dates specified below have passed. Employment application materials for individuals who were not hired are also to be shredded. Electronically store information will be erased and/or deleted.

When paper records must be destroyed, records may be shredded using a locked shredder on the KBP premises. Remote employees are discouraged from printing out or creating hard copies of confidential records where possible. If hard copies must be printed, created or kept, they should be stored in a locked cabinet, drawer or other secure location until they are no longer needed, or until the maximum retention period has ended. Remote employees must then destroy all confidential files by shredding them in a locked shredder on KBP premises, or otherwise rendering the documents unusable or unreadable.

The HR department will work with the IT department to ensure that the HR department’s electronic records relating to employee information and compliance reports are properly erased.

Litigation Hold

When KBP is involved in or anticipates that it may be involved in litigation, a litigation hold may be issued, which means that all documents relating to the litigation matter must be kept to preserve any potential evidence.
If a litigation hold is issued, all records covered by that litigation hold MUST NOT be discarded, deleted or destroyed. Further, the IT department will suspend the automatic deletion of emails for all individuals covered by the litigation hold.

Record Types and Retention Periods
Health & Benetifs Records
Health & Benefits Benefiacary Forms Termination + 6 yrs.
Medical, Dental/Vision Plan Elections Termination + 6 yrs.
Drug Test Results Termination + 6 yrs.
Education Assistance Program Records Termination + 6 yrs.
Medical Leave Records Termination + 6 yrs.
Military Leave Records Permanent
Toxic & Bloodborne Pathogens Records Termination + 30 yrs.
Job Related Injuries & Illnesses Records Termination + 6 yrs.
Reasonable Accommodation Records Termination + 6 yrs.
Pre-Employment and Personnel Documents*
* Note: If an applicant is not hired, the following Pre-Employment and Personnel Documents records should be retained for two (2) years after the no-hire decision is made.
Job Desctiption Termination + 6 yrs.
Recruitment Notice/Job Aids Termination + 6 yrs.
Employment Application/Resume Termination + 6 yrs.
Interview Evaluation Termination + 6 yrs.
Assessment Results Termination + 6 yrs.
Background Check Information Termination + 6 yrs.
References/Verifications Termination + 6 yrs.
Offer Letter Termination + 6 yrs.
Form I-9 Termination + 6 yrs.
EEO Data Form Termination + 6 yrs.
Employee Policy Acknowledgements Termination + 6 yrs.
Intellectual Property Ownership/Nondisclosure Termination + 6 yrs.
Employee Change Action Documents Termination + 6 yrs.
Disciplinary Records Termination + 6 yrs.
Employee Development Records Termination + 6 yrs.
Position/Pay History Records Termination + 6 yrs.
Employee Performance Review Termination + 6 yrs.
Resignation Letter Termination + 6 yrs.
Termination Action Form Termination + 6 yrs.
COBRA Election Notice Termination + 6 yrs.
Separation Agreement Termination + 6 yrs.
Exit Interview Form Termination + 6 yrs.
Unemployment Claim Records Termination + 6 yrs.
Retirement
401(k) Allocation Records Termination + 6 yrs.
401(k) Loan Payment Forms Termination + 6 yrs.
Pension Eligibility Records Permanent
Request for Calculation Termination + 6 yrs.
Retirement Beneficiary Form Permanent
Payroll/Tax
W-2s, W-4s Termination + 6 yrs.
Paychecks/stubs Termination + 6 yrs.
Earnings Register Termination + 6 yrs.
Employee Withholding Termination + 6 yrs.
Expense Reports Termination + 6 yrs.
Federal & State Payroll Tax Forms Termination + 6 yrs.
Time Sheets/Cards Termination + 6 yrs.
Direct Deposit Records Termination + 6 yrs.
Garnishment Records Termination + 6 yrs.
HR Policies & Reports
EEO-1 Reports Permanent
HR Policies While current + 3 yrs.
Affirmative Action Plans/Records While current + 6 yrs.
Form 5500 6 yrs.
OSHA 300/300A Posting date + 5 yrs.
VETS-4212 Reports 5 yrs.
Unemployment Claim Records Termination + 6 yrs.
    09.2023