Maintaining accurate personnel records is critical to effective human resource management and to the Board of
Education satisfying its legal obligations. In addition, such records frequently contain confidential information that
must be managed appropriately. Accordingly, the Board has developed the following policy relating to personnel
District Records Officer Designation and Responsibilities
The Board designates the Director of Human Resources as the District Records Officer (DRO). The 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. The DRO will also ensure that the following personnel records, if
applicable, are maintained 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 investigative and deliberative
records relating to employee relations matters
D. Privileged and confidential communications including, but not limited to, attorney-client communications
Any individual who reviews personnel records will sign and date a log, which shall be kept in a secure location.
Content of Personnel Record Files
The content of the files maintained by the District shall be determined by the DRO consistent with the
requirements of State and Federal law and sound principles of human resource management.
Third-Party Access to Personnel Records – Confidentiality
It is the Board’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 Board’s interest. Information in an
employee’s personnel file, medical file, payroll 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 Board or as required by law (e.g. subpoena or public record request). Further, neither the Board nor any
individual employed by the Board shall access an employee’s personnel records except for legitimate business
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. Letter 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.
B. 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 policy.
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.
C. 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 procedure.
D. 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 the 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