HR Documentation Standards: If It Isn't Written, It Didn't Happen
The documentation discipline that protects employees, managers, and the company in equal measure. What to write, when, in what system — and what never to put…
- Documentation is the cheapest insurance any HR function buys.
- Use the BIFF rule: Brief, Informative, Factual, Friendly.
- Separate the personnel file (formal) from the working file (manager notes).
- Never put conclusions in writing before the process is complete.
- Retain by jurisdiction, not by convenience.
Every HR professional learns this the first time a case goes to tribunal: the file is the case. Memory fades, witnesses leave, Slack history rolls off — what survives is what was written down and how it was stored.
Two files, one record
- Contract and amendments
- Formal performance reviews
- Disciplinary outcomes
- Grievance and investigation reports
- Compensation history
- Training records
- Subject to data-access requests
- 1:1 notes
- Coaching observations
- Draft feedback
- Patterns the manager is watching
- Not formal, but discoverable in litigation
- Should still follow BIFF
The BIFF rule
- 1BriefShort. The longer the note, the more attack surface in a tribunal.
- 2InformativeDate, time, who was present, what was said or done. No adjectives unless quoting.
- 3FactualObservable behavior, not interpretation. 'Raised voice and slammed laptop' — not 'was aggressive'.
- 4FriendlyNeutral tone. Assume it will be read by the subject, their lawyer, and a judge.
What belongs where
| Event | Personnel file | Working file | Neither (don't write) |
|---|---|---|---|
| Annual review | Yes | Drafts only | — |
| 1:1 note | No | Yes | — |
| Verbal warning | Yes — letter confirming verbal warning | Manager's contemporaneous note | — |
| Hallway complaint about a peer | No — until formalised | Yes — dated, BIFF | — |
| Speculation about someone's health, religion, sexuality | Never | Never | Yes — never write |
| Investigation report | Yes — confidential access | No | — |
Retention by jurisdiction
Retention periods vary widely — US federal baselines under EEOC, ADEA, and FLSA range from 1 to 4 years; EU GDPR demands proportionality and a defined purpose; UK ACAS guidance suggests 6 years post-employment for most records. Build a retention schedule per jurisdiction, automate deletion, and document the schedule itself.
'I think she just doesn't like working here.' Conclusions, opinions, and speculation about state of mind do not belong in any HR record. Behavior and dates do.
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