Spring cleaning: 4 often-overlooked rules on personnel records.

• Position: Nuts & Bolts

"Into the cabinet it goes, I'll deal with it later" This is, too often, the dangerous generic policy adopted by harried HR pros when dealing with the daily onslaught of employee paperwork.

If you're planning a spring cleaning of personnel records, take a look at the big picture of your record-keeping practices to avoid cutting corners--and opening yourself to litigation worries. Four rules to focus on:

1. Separation of files

   Got one big folder with an employee's entire history in it? Big mistake. An employee's personnel file should only hold information related to compensation, performance reviews, discipline, training records and documents like recognition and rewards.

   The following are required to be maintained separately:

   * 1-9 forms.

   * Pension or 401(k) information.

   * Medical/disability records, including FMLA requests and paperwork.

   * Results of drug and alcohol tests.

   * Investigation files on serious incidents, such as workplace violence or harassment.

2. Records on ex-employees and rejected applicants

   Several federal laws require that you save submitted applications for at least one year. It's safest to hold onto them for up to two years. For those who are hired, retain their applications throughout their employment and three years beyond. Apply the same rule to interview notes.

   When an employee leaves, it's still recommended that you keep a strict system of separating those files as noted. I-9 forms are of particular concern; keep them on file three years after the date of hire or one year after the employee's termination date, whichever is later.

3. Structure of discipline notes

   You can be held liable for actions against employees if the information in their personnel files is faulty or discriminatory. Any log kept on an employee should not include:

   * Information about the employee's family, ethnic background, beliefs or medical history.

   * Theories about why the employee is behaving a certain way.

   * Opinions about the employee's career prospects.

   * Unsubstantiated complaints against the employee.

   * Rumors or speculation about the employee's personal life.

   * Nonwork-related information the employee posted or that was posted about the employee on social media.

   Such a log may include things like contemporaneous notes on work performance (pro and con), instances of absences/tardiness, disciplinary discussions and details of interactions with the worker.

   Beware of pesky "desk files" that managers keep informally on their employees. Desk...