Number: HR 090
Effective: April 4, 2009
Department: Human Resources
Last Revision: May 8, 2020


To provide guidelines for the maintenance of and access to employee personnel records.


Applies to all CWI employees and prospective employees.


Personnel records: name-linked files of and documents related to potential, current and former employees of CWI.


CWI recognizes that it has an obligation to individuals who apply for or who are employed by CWI to protect their personal information. Further, CWI recognizes its obligation to provide for the maintenance of and access to employee personnel records pursuant to applicable law. Accordingly, this policy sets forth guidelines for the proper maintenance of and access to personnel records.


CWI’s official personnel records will be kept in the office of Human Resources.  These personnel records shall include all records of employee performance evaluations, employee status, and other relevant materials related to the employee's service with CWI.  Each employee shall have the right to review all materials placed in his/her official personnel file at any reasonable time.  Copies of materials in an employee’s official personnel file are available to that employee without charge.  Personnel files shall not be removed from the premises except as necessary for CWI purposes.

Applicant interview notes will be maintained by the hiring manager for a minimum of three (3) years.

Contents of CWI Personnel Files

CWI’s official personnel files consist of an individual’s employment-related information including: employment applications, offer letters, fully executed employment contracts, compensation information and changes, personnel changes, performance evaluations, formal performance-related communications to employee, formal disciplinary documents, policy acknowledgements, and separation documents.

Employee benefit files are also maintained in the office of Human Resources and are sept separate from the official personnel file.  Benefit files include but are not limited to:  employee benefit enrollment forms, benefit elections, benefit declination forms, beneficiary designations, leave requests and leave donations.   

Supervisors are not permitted to maintain duplicate personnel records or personally identifiable information contained in personnel or benefit files, such as social security numbers, I-9 information or health information/provider documentation.  Supervisor documentation, not including the foregoing, may be maintained in hard copy or digital format in supervisor files.

Third Party Requests for Personnel Records

Personnel information and personnel records will only be provided to outside parties with consent from the employee, when deemed necessary by CWI’s legal counsel, pursuant to court order or proper subpoena or as otherwise authorized by law.  CWI reserves the right to disclose the contents of personnel files to outside state or federal agencies, to its insurance carrier or its agents for risk management purposes, or to its lawyers when necessary for defending itself against allegations of unlawful conduct.

Upon receipt of a subpoena for the production of personnel records, an appropriate CWI official, in consultation with CWI’s legal counsel shall:  (i) make every reasonable effort to immediately notify the person affected by the subpoena and confirm such notice in writing; and (ii) gather the information requested by the subpoena for response.  Employee personnel records are considered to be private and confidential.  Only personnel with a legitimate need to know shall have access to employee personnel records.

Objecting to the Contents of Personnel Files

Each employee shall be provided an opportunity to contest the contents of his/her official personnel file at any time.  The employee must file a written objection and explanation, which will be included in the file along with the objectionable material.  In the sole judgment of the supervising official, after consultation with CWI’s legal counsel, any offending material may be removed upon a showing by the employee that it is false or unfairly misleading.  In general, there should be a presumption that materials are to remain in personnel files accompanied by the employee’s written objection and explanation to provide a complete employment history of each individual.