We recommend having five separate files for each employee, as outlined below:

• I-9 file: Keep all Form I-9s in a separate master file or three-ring binder.
• Medical file: This file should contain everything related to an employee’s medical history, including health insurance enrollment forms. It’s important to separate this file because you cannot legally base personnel decisions, such as who gets promoted and who doesn’t, on an individual’s medical history. In addition, various privacy laws and the Americans with Disabilities Act (ADA) require that you keep confidential employee medical records separate from basic personnel files. The retention period will depend on the type of record.
• Personnel file: This file should contain items that were a factor in the employee’s hiring and employment in addition to items that will have any impact on their employment in the future. This includes performance reviews and corrective action records.
• Payroll records file: This file should contain the employee’s W-4 and any other payroll-related documents containing the employee’s SSN or other protected information, including garnishments.
• Injury file: Keep a file for any employee who is injured while on the job. This file should contain workers’ compensation claim records and injury reports, and any additional medical records pertaining to the injury. It’s okay to start this file only if an employee suffers an injury on the job.

These files should be kept in a secure location that is only accessible to those in the HR function or with a legitimate need to review the information—for instance, in locked cabinets inside a locked HR office. This information can be stored electronically if that makes more sense for your church. Just ensure that it’s well secured and backed up to prevent data loss.

Clergy Financial Resources serves as a resource for clients to help analyze the complexity of clergy tax law, church payroll & HR issues. Our professionals are committed to helping clients stay informed about tax news, developments and trends in various specialty areas.

This article is intended to provide readers with guidance in tax matters. The article does not constitute, and should not be treated as professional advice regarding the use of any particular tax technique. Every effort has been made to assure the accuracy of the information. Clergy Financial Resources and the author do not assume responsibility for any individual’s reliance upon the information provided in the article. Readers should independently verify all information before applying it to a particular fact situation, and should independently determine the impact of any particular tax planning technique. If you are seeking legal advice, you are encouraged to consult an attorney.

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