This is a fairly common issue in many organizations, not simply the
small ones. In my organization, HR has "deputized" particular Records
associates who are able to handle their files. (In effect, it is
building a level of trust between HR and the associates who are given a
more extensive briefing on confidentiality and the implications of
breaching that with associate records.) Generally, this has been the
more senior associates and supervisors. Our active HR files are
maintained in another building and HR sends boxes of files to Records
in sealed plastic tote boxes (the tote box is large enough to
accomodate a standard records center carton). Generally the onsite
retention for terminated associate files is several years so that helps
to mitigate any curiosity factor that someone might have when
terminated files show up. We process the files like all other files
(index at the file level) and ship the boxes offsite (we do not put
anything on our boxes but a bar code and we don't inform the records
center of the box contents).

HIPPA-protected documents are still closely held and associate
investigations and complaints are not sent to Records.

Much of this is about to change as our internal HR department is in the
process of being treated as an outsourcing client by our HR outsourcing
business. In effect, they will begin to look like any other client's HR
department to us.

Patrick Cunningham, CRM

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