Electronic Employee Records – What Are They and How Long Must They Be Stored?

What Are Electronic Employee Records and How Do They Work?

Electronic employee records are the digital equivalent of traditional employee files, enabling secure and organized storage of documents in electronic form. In practice, they function as files saved in an encrypted database, which can be quickly searched, shared online, and managed with automatic version control and access supervision. Electronic employee records have been legally permitted since January 1, 2019.

Structure of the Electronic File: Parts A, B, C, D, and E

The structure of electronic employee records is defined by regulations and maintains the same organization as its paper counterpart. According to current regulations, it consists of five parts labeled with letters:

• Part A – contains documents related to job application, personal data, and medical examinations;
• Part B – collects documents concerning the establishment and course of employment (contracts, job descriptions, confirmations of familiarization with regulations);
• Part C – includes documents related to termination or expiration of employment;
• Part D – contains documents related to employee disciplinary responsibility;
• Part E – holds documents related to sobriety checks or presence of other intoxicants.

All documents in the electronic file must be arranged chronologically, and each part should include a list of the documents it contains.

Differences Between Electronic and Paper Files

Electronic employee records differ from paper files in many ways—from storage methods to everyday usability:

• Access to documentation – electronic employee records are available 24/7 from any location, while paper files require physical presence. Processing documents electronically is automatic and fast, whereas paper processing is manual and time-consuming.
• Storage space – electronic storage systems do not require physical space, eliminating the need for printing. Additionally, searching electronic HR documentation can be done in seconds.

GDPR Compliance and Data Security of Electronic Employee Records

Maintaining electronic employee records requires meeting detailed personal data protection requirements, such as:

• Access limited only to authorized personnel, with each user having an individual login linked to their name;
• Electronic employee records must be signed with a qualified electronic signature or qualified electronic seal;
• Use of data encryption, backup creation, and change history logging;
• Ability to identify persons making modifications to documents.

According to GDPR, appropriate procedures and solutions must be implemented to minimize the risk of accidental disclosure of data contained in employee documents. Electronic employee records enhance data security by protecting against loss, destruction, unauthorized editing, or copying.

How Long Is the Mandatory Retention Period for Electronic Employee Records?

The mandatory retention period for electronic employee records (the same as for paper records) depends on the employment start date:

• 10 years – for employees hired from January 1, 2019, or those whose documentation has been converted to electronic records in accordance with new regulations.
• 50 years – for employees hired before January 1, 2019, unless the employer submits an informational report to ZUS (form ZUS RIA) – then the retention period is also shortened to 10 years.

The legal basis is Article 94 point 9b of the Labor Code and the Act of January 10, 2018, on amending certain laws related to shortening the retention period of employee records.

7 Processes After Implementing Electronic Employee Records

Implementing electronic employee records changes the way daily HR processes function. Here are seven key areas requiring a new approach after switching to digital documentation:

1. Reviewing the employee’s electronic file in the system

Electronic record-keeping allows instant searching for specific information using metadata and keywords. Only authorized persons with individual logins should have access. The system must automatically log all management activities, e.g., who and when added or deleted a document.

2. Adding documents to the electronic file

Managing employee documentation electronically is much simpler. Adding a new document involves selecting the employee, attaching the file, filling in required fields, and saving changes. Documents can be scanned originals or digital files, each assigned a unique number following a standard numbering scheme. Modern systems also generate reports on missing documents, allowing HR to quickly identify gaps (e.g., current medical exams, safety training, declarations). They also monitor document expiry dates and send automatic reminders, reducing the risk of non-compliance.

3. Automatic saving of electronic requests and pay slips

The system automatically archives electronic pay slips and makes them available to employees via a portal. All employee-submitted electronic requests are also saved in the electronic file.

4. Time tracking without paper lists

Electronic time tracking eliminates the need for printing traditional attendance lists. The system automatically records presence, overtime, and absences. Sick leaves can be imported directly from the ZUS PUE system.

5. Vacation management via Employee Portal

Employees submit vacation requests online without paper forms. After logging in, they select dates, type of leave, and add descriptions. The request is automatically sent to the supervisor for approval or rejection, and the employee receives immediate notification.

6. Deleting documents after penalty expiry

Disciplinary penalties expire after one year of impeccable work (employers may recognize earlier expiration). After employment ends, references must be removed no later than one year after the penalty was imposed.

7. Issuing copies of documents to employees

Upon employee request, the employer must provide a copy of the employee’s documentation in electronic or paper form within 30 days. Electronic copies may include metadata and the employer’s signature confirming conformity with the original.

Comparison: Electronic vs. Traditional Employee Records

The electronic circulation of employee documents compared to paper documentation brings many benefits, including faster management of employee records, easier access to personal documents, and lower operational costs.

Document processing time

Digitizing employee records significantly reduces the time spent on documentation. Scanning and automatic indexing take only a fraction of the time needed for searching, copying, and labeling paper files. This makes record handling much faster and more efficient.

Accessibility and data searching

Electronic records provide instant online access to documents from any location, while traditional documentation requires physical presence in the archive. Electronic systems allow rapid searching by name, date, or document type. Multiple authorized users can access records simultaneously, eliminating wait times. This is especially useful in larger organizations.

Cost of storing electronic employee records

Storing employee records digitally reduces expenses related to printing, storage, and archiving paper documents. Digital documentation requires no physical space, saving on office rental costs. It also lowers the risk of document damage from flooding or fire, providing additional protection for long-term archiving.

Compliance with regulations and audits

Maintaining electronic employee records requires strict adherence to archiving regulations. Many software solutions offer automatic scheduling of document retention, facilitating compliance with required storage periods. Digital storage also enables quick preparation of documentation for inspections, simplifying audit processes.

Summary of Maintaining Electronic Employee Records

Electronic employee records are a digital form of the traditional employee file, compliant with regulations since 2019. They allow quick document access, automate HR processes, save space, and enhance data security. The retention period is 10 years for employees hired from 2019 or after submitting the ZUS RIA report, and 50 years for employees hired earlier.

If you want to implement electronic circulation of employee documents and maintain electronic employee records, the Evotax team is here to help! Contact us, and our specialists will gladly provide support!

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