The Ohio State University – University Policies policies.osu.edu Page 1 of 4
Personnel Records, 1.20
University Policy
Applies to: Faculty, staff, graduate associates, and student employees
Responsible Office Office of Human Resources
POLICY
Issued: 10/01/1977
Revised: 06/10/2024 (minor revision)
University personnel records should be accurate, relevant, and safe from improper disclosure. Sound personnel decisions
require that the university collect and retain information concerning employment history and performance. Personnel
records are public records subject to exemptions set forth in Ohio law. Federal and state laws require that certain
information be gathered and maintained in personnel files.
Purpose of the Policy
To provide guidance on how to assemble and maintain personnel files and other personnel records.
Definitions
Term
Definition
Education records
Any records, other than directory information (e.g., name and address), directly related to a student and
maintained by the university, including employment records of an individual employed as a result of their status as
a student.
Centers of Expertise
(CoE)
Teams in the Office of Human Resources who provide specialized services based on their specific subject
matter expertise.
Intellectual property
records
Most research-related information, other than financial or administrative data, that has not previously been publicly
released, published, or patented.
Investigatory records
Primarily the records of a police department, but also includes, but is not limited to, administrative investigations.
Medical records
Any documents pertaining to medical history, diagnosis, prognosis, or medical condition that are generated and
maintained in the process of medical treatment.
Personnel file
A specific type of personnel record that is an employee’s official file containing records that serve as a
chronology of the employee’s history with the university.
Unit
College or administrative unit.
Policy Details
I. Personnel Files
A. Creation and contents
1. Each employee only has one university personnel file, which is maintained by the employing unit.
2. An employee's personnel file contains only necessary job-related information, as outlined in Procedure
I.A.
a. Personnel records must be shared with the employee prior to being placed in the personnel file.
b. Records contained in the Human Resources Information System may also be considered part of the
personnel file. These records are not a substitute or replacement, nor do they alone meet the
requirements for each employee having a personnel file.
B. Personnel records to be maintained separately from the personnel files
1. Education records, intellectual property records, investigatory records, medical records, promotion
and tenure records, and attorney-client privileged communications are controlled access records and are
not part of the personnel file.
2. The Office of Academic Affairs is responsible for maintaining the official promotion and tenure records
for faculty members as the office of record.
Personnel Records, 1.20
University Policy
Applies to: Faculty, staff, graduate associates, and student employees
The Ohio State University – University Policies policies.osu.edu Page 2 of 4
C. Transfer and rehire
1. When an employee transfers from one unit to another, the personnel file and controlled access records
become the responsibility of the new unit’s Human Resource Business Partner (HRBP) or designee.
2. When an employee is rehired by the university:
a. If their former personnel file is still active, new records must be added to the existing personnel file.
b. If their former personnel file is inactive or has been deleted in accordance with the university’s
record
retention schedule, a new personnel file must be created.
D. Records retention
1. Centers of Expertise (COEs) within the Office of Human Resources (OHR) and unit HRBPs or
designees must adhere to the applicable records retention schedule(s).
2. Each record within the personnel file must be maintained or destroyed according to the university or unit
retention schedule for that specific record.
3. For more information, see the university's retention schedules webpage f
or the OSU General Records
Retention Schedule and Unique Retention Schedules.
II. S
upervisory Files
A. If a supervisory file exists for the employee, it is not part of the personnel file and must be maintained in a
secure location by the employee’s manager.
B. See Personnel File Setup
for more information on supervisory f
iles.
PROCEDURE
Issued: 10/01/1977
Revised: 06/10/2024 (minor revision)
I. Creation and Maintenance of Personnel Files
A. Requirements for creating employee personnel files are found in Personnel File Setup.
B. CoEs and unit HRBPs or designees must place records in the personnel file consistent with Personnel File
Setup.
C. The personnel file must be maintained consistent with the Institutional Data policy.
II. Employee Transfer Impact on Personnel File Maintenance
A. When an employee transfers from one unit to another, the personnel file and the employee’s controlled access
records become the responsibility of the HRBP or designee of the new unit.
III. Access to Personnel Files
A. In accordance with and to the extent permitted by the Ohio Public Records Act,
employees may request to
inspect or obtain a copy of their own personnel file. Current employees should contact their unit HRBP or
designee, who will respond to such requests within a reasonable period of time.
B. A re
quest for internal access to another individual’s personnel file should be made to the appropriate HRBP
or designee. The HRBP or designee will ensure the requestor has a legitimate job-related need to access the
file, and will respond to such requests within a reasonable period of time.
C. Former employees may request a copy of their personnel file from Employee and Labor Relations
(ELR).
ELR will consult with the Office of University Compliance and Integrity (OUCI), Public Records, prior to
responding to the request.
D. R
equests for personnel files other than requests described in Procedure III.A are generally considered public
records requests and should be processed accordingly. For more information, see the Public Records policy.
Personnel Records, 1.20
University Policy
Applies to: Faculty, staff, graduate associates, and student employees
The Ohio State University – University Policies policies.osu.edu Page 3 of 4
IV. Disputing Information in the Personnel File
A. Employees who question the accuracy or completeness of information in their personnel files should
discuss their concerns with the appropriate HRBP or designee.
B. The HRBP or designee will consider the objections and determine the appropriate resolution.
1. Should the disputed information be retained in the file, the employee may submit a brief written statement
which identifies the alleged errors or inaccuracies. The statement will remain in the file as long as the
disputed information is retained.
2. Should the disputed information be removed from the file, its removal must be documented.
V. Public Records Requests for Personnel Files
A. Records maintained in a personnel file are generally considered public records under Ohio law. When a
public records request is made, documents or information such as social security numbers, driver’s license
information, home addresses, personal telephone numbers, email addresses, and employee ID numbers may
require redaction or withholding pursuant to law.
B. For guidance concerning public records requests for personnel files, contact:
1. The appropriate HRBP or designee,
2. The appropriate ELR
c
onsultant in OHR, or
3. For non-routine requests, OUCI, Public Records.
C. When a public records request is made to examine the personnel file of a current employee (excluding those
described in Procedure III.A), to the extent practical, the responding university office will attempt to notify
the employee of the request.
D. The university may verify information (e.g., employment status, job title) without notifying the
employee involved.
E. The university will cooperate as appropriate with law enforcement investigators, public safety officers,
and other officials as necessary.
Responsibilities
Position or Office
Responsibilities
Centers of Expertise (CoE)
1. Ensure that personnel files are maintained consistently with applicable records retention schedule(s).
2. Ensure contents of personnel file are consistent with Personnel File Setup requirements.
Employee and Labor
Relations (ELR)
Consult with OUCI prior to responding to former employees’ requests for copies of their personnel files.
Employing unit
Maintain personnel files.
Human Resource Business
Partner (HRBP) or designee
1. Ensure each employee has a personnel file that is retained consistently with the university’s retention
schedule.
2. Ensure contents of personnel file are consistent with Personnel File Setup requirements.
3. Process requests for personnel files as set forth in the policy.
4. Consult with ELR regarding notifying employees, when practical, when public records requests
have been made for their personnel files.
5. Provide guidance concerning public records requests for personnel files.
Office of Academic Affairs
(OAA)
Maintain official promotion and tenure records for faculty members.
Office of University
Compliance and Integrity,
Public Records
Provide guidance concerning non-routine public records requests for personnel files.
Personnel Records, 1.20
University Policy
Applies to: Faculty, staff, graduate associates, and student employees
Page 4 of 4
Resources
University Policies, policies.osu.edu
Institutional Data policy, go.osu.edu/idp
Public Records policy, go.osu.edu/public-records-policy
Privacy and Release of Student Education Records policy,go.osu.edu/student-records-policy
Additional Guidance
Family Educational Rights and Privacy Act (FERPA), www2.ed.gov/policy/gen/guid/fpco/ferpa/index.htmlNon-R
equired
Personnel Documents Classifications (for electronic personnel files), hr.osu.edu/wp-content/ uploads/policy120-nonrequired-
personnel-docs.pdf
Ohio Public Records Act, codes.ohio.gov/ohio-revised-code/section-149.43
OSU General Records Retention Schedule, go.osu.edu/retention-schedules
Personnel File Setup, hr.osu.edu/wp-content/uploads/policy120-personnel-file-setup.pdf
Personnel Records Frequently Asked Questions, hr.osu.edu/wp-content/uploads/policy120-faq.pdf
Required Personnel Documents Classifications (for electronic personnel files), hr.osu.edu/wp-content/uploads/ policy120-
required-personnel-docs.pdf
Contacts
Subject
Office
Telephone
E-mail/URL
Office of Academic Affairs
614-292-5881
oaa.osu.edu
Office of Legal Affairs
614-292-0611
legal.osu.edu
Public Records, Office of University
Compliance and Integrity
614-292-6459
publicrecords@osu.edu
compliance.osu.edu/public-records
HR Connection
614-247-myHR (6947)
HRConnect[email protected]
HR Connection
614-247-myHR (6947)
HRConnect[email protected]
History
Issued: 10/01/1977
Revised: 10/01/1980
Revised: 03/21/1997
Edited: 11/20/2000
Revised: 06/05/2002
Edited: 08/26/2002
Edited: 01/23/2006
Reviewed: 09/01/2004
Revised: 05/01/2012
Revised: 06/15/2017
Edited: 01/22/2021 Added HR Connection contact information
Revised: 06/10/2024 Minor revision
The Ohio State University – University Policies policies.osu.edu