8320 Operations_Personnel Records

Maintaining accurate personnel records is critical to effective human resource management and to the District
satisfying its legal obligations. In addition, such records frequently contain confidential information that must be
managed appropriately. Accordingly, the District has developed the following administrative guideline relating to
personnel records.
Location and Maintenance – Personnel File, Payroll File, I-9 File, and Medical File
The District Records Officer (DRO) will maintain a personnel file, a payroll file, an I-9 file, and a medical file for each
employee. The files will be maintained in separate, secure locations. Supervisors and other administrators should
forward all personnel records, I-9 records, payroll records, and medical records to the DRO to ensure that they are
properly filed and maintained. Supervisors and other administrators should not maintain files containing an
employee’s personnel records, payroll records, I-9 records, or medical records. Further, neither the Board nor any
individual employed by the Board shall access an employee’s personnel records except for legitimate business
purposes. Any individual who reviews personnel records will sign and date a log, which shall be kept in a secure
Personnel File Records
An employee’s personnel file will contain the following records (if applicable):
    A. Completed employment records
    B. Offer letter
    C. Acceptance letter
    D. Emergency contact information
    E. Written requests to review the personnel file
    F. Letters of commendation
    G. Academic or other achievement records
    H. Training records
    I. Records relating to final disciplinary actions (e.g., written warning for excessive absenteeism)
    J. Leave request forms and supporting documentation; provided, however, that all such documents should have
        all medical information removed
    K. Written requests to review the personnel file
    L. Grade transcript(s)
    M. Completed right-to-know forms
    N. Current name, address, and telephone number
    O. An accurate record of work experience
    P. Proof of fulfillment of requirements for change in salary classification
    Q. Current information pertaining to certificates required by the State
    R. Record of assignments
    S. Proof of discharge from military service
    T. Rate of compensation
    U. Completed evaluations
    V. Special awards or distinctions
Payroll File Records
An employee's payroll file will contain the following records (if applicable):
    A. W-4 forms
    B. Direct deposit authorization
    C. Consent to payroll deductions
    D. Beneficiary designation forms
    E. Retirement registration
    F. Life and disability insurance forms, without medical information
    G. Completed annuity forms
Medical File Records
An employee’s medical file will contain the following records (if applicable):
    A. Medical records, notes, or other documents containing medical information including, but not limited to,
        records containing physical limitations.
    B. Medical records relating to leaves of absence for medical reasons, including, but not limited to, Family and
        Medical Leave Act leave and sick leave, (e.g., medical certification forms, requests for leave, and fitness for
        duty statements).
    C. Workers’ compensation records and supporting documentation including, without limitation, physician notes
        relating to an employee’s ability to return-to-work and an employee’s physical limitations.
    D. All occupational exposure and medical records that the District is required to maintain under the
        Occupational Safety and Health Act.
    E. Requests to review the medical file.
I-9 File Records
The I-9 file will contain records required by the Immigration Reform and Control Act of 1986 including, but not
limited to, the form I-9 and supporting documentation.
Other Personnel Records
The District will maintain the following personnel records (if applicable) in separate, secure files:
    A. Criminal conviction history requests and reports
    B. Employee assistance program records
    C. Employee relations complaints including, for example, discrimination complaints
    D. Investigative and deliberative records relating to employee relations matters
    E. Privileged and confidential communications including, but not limited to, attorney-client communications
Third-Party Access to Personnel Records – Confidentiality
It is the District’s policy to respect individual privacy and to maintain in confidence all information and records
pertaining to employees to the extent practicable in keeping with the District’s interest. Information in an
employee’s personnel file, medical file, I-9 file, and all other employment-related files will not be disclosed to any
third party without an employee’s written consent, except to meet the legitimate business needs of the District or
as required by law (e.g., subpoena or public record request).
Access to Personnel Documents, Employee and Designated Representative
A. Covered Documents
    Upon the written request of an employee or former employee (the "employee"), the District shall permit the
    employee to inspect any personnel documents which are used or which have been used in determining that
    employee’s qualifications for employment, promotion, transfer, additional compensation, termination or other 
    disciplinary action, and medical records. Provided, however, that the employee has no right to inspect the
        1. Records relating to the investigation of possible criminal offenses committed by that employee
        2. Letters of reference for that employee
        3. Any portion of a test document, except that the employee may see a cumulative total test score for either
            a section of the test document or for the entire test document
        4. Materials used by the District for staff management planning, including judgments or recommendations
            concerning future salary increases and other wage treatments, management bonus plans, promotions and
            job assignments, or other comments or ratings used for the District’s planning purposes
        5. Information of a personal nature about a person other than the employee if disclosure of the information
            would constitute a clearly unwarranted invasion of the other person’s privacy
        6. Records relevant to any other pending claim between the District and the employee which may be
            discovered in a judicial proceeding
    7. Medical records that the District believes would have a detrimental effect on the employee
        In this instance, the District may release the medical records to the employee’s physician or through a
        physician designated by the employee, in which case the physician may release the medical records to the
        employee or to the employee’s immediate family.
    8. Request and Review Procedure
        The District shall grant at least two (2) requests by an employee in a calendar year, unless otherwise
        provided in a collective bargaining agreement, to inspect the employee’s records as provided in this guideline.
        The District shall provide the employee with the opportunity to inspect the employee’s records within seven
        (7) working days after the employee makes the request for inspection. The inspection shall take place at a
        location reasonably near the employee’s place of employment and during normal working hours. If the
        inspection during normal working hours would require an employee to take time off from work, the District
        may provide some other reasonable time for the inspection. In any case, the District may allow the inspection
        to take place at a time other than working hours or at a place other than where the records are maintained if
        that time or place would be more convenient for the employee. The records will be reviewed in the presence of
        the DRO or a designee. 
        The employee shall not make any alterations or additions to the record nor remove any material from the
        record. A copy of the employee’s request to review personnel records shall be filed in the employee’s
        personnel file.
    9. Designated Representative
        An employee who is involved in a current grievance against the District may designate a representative of the
        employee’s union, collective bargaining unit, or other representative to inspect the employee’s personnel
        records, which may have a bearing on the resolution of the grievance. The designation shall be in writing. The
        District shall allow such a designated representative to inspect that employee’s personnel records in the
        same manner as the employee is permitted to inspect them under this guideline.
    10. Copy Charges
        The District will not charge employees who wish to copy or receive a copy of records.
Personnel Record Correction
If an employee disagrees with any information contained in the personnel records, a removal or correction of that
information may be mutually agreed upon by the District and employee. If an agreement cannot be reached, the
employee may submit a written statement explaining the employee’s position. The District shall attach the
employee’s statement to the disputed portion of the personnel record. The employee’s statement shall be included
whenever that disputed portion of the personnel record is released to a third party as long as the disputed record is
a part of the file.
103.13, Wis. Stats.
The Americans with Disabilities Act of 1990
Approved/Adopted:  July 13, 2009
Sharon Weinstock,
Aug 3, 2011, 11:59 AM