Employee Records
Part of HR reporting and workforce data
Separating people data from unsupported performance judgments
Use HR figures as observations, check their limits and seek specific evidence before making performance judgments about employees or managers.
People data can describe recorded events. On its own, it cannot establish an employee’s ability or effort, or a manager’s quality.
Before using an HR figure in a performance discussion, name the observation, check the underlying record and identify what further evidence a judgment would need.
State what was observed
A report may show assigned work was marked complete, a shift was missed or several people left a team. Each statement is narrower than “the employee is ineffective” or “the manager drove people away”. The wider claim needs context and an appropriate assessment process.
| Part | Illustrative entry |
|---|---|
| Observation | “Three assigned tasks show a completed status by 30 September.” |
| Limit | “The status does not show the quality of the work.” |
| Follow-up | “Review the work against the agreed task requirements and ask about any discrepancy.” |
This is a hypothetical example. Absence dates and codes likewise describe recorded leave; they do not establish its cause or a person’s commitment.
Check whether each observation comes from a record the employer must keep. Employers are legally required to keep some employment records for 7 years, including hours of work and overtime and leave taken and accrued, and rosters and timesheets record when staff were required to work. Point each observation to the record it came from.
Check data and context
Ask where the figure came from, which period it covers and whether corrections remain open. Check whether the person had the opportunity, equipment and assigned work assumed by the metric. A delayed approval can alter a completion date without changing what the employee did. A team total can conceal changes in staffing or work allocation.
Where the Australian Privacy Principles apply, APP 10 on the quality of personal information, explained in chapter 10 of the OAIC’s APP guidelines, requires reasonable steps to ensure personal information used or disclosed is accurate, up to date, complete and relevant to the purpose.
Whether the APPs apply depends on the employer. The Privacy Act 1988 treats public and private employee records differently: for Australian Government employees, the APPs apply to personal information in current and past employee records. A private sector employer's handling of employee records is exempt if it is directly related to the current or former employment relationship.
The Privacy Act applies to a private sector employee record only if the information is used for a purpose not directly related to the employment relationship. Even where the exemption applies, accurate records remain the basis of a fair judgment, so apply the same quality checks.
Key Legal Requirements for Employee Records in Australia
- Records to Keep (7 Years)
- Hours of work, overtime, leave taken and accrued, rosters, timesheets
- APP 10 – Quality of Personal Information
- Must be accurate, up to date, complete, and relevant
- Private Sector Exemption
- Employee records exempt if used only for employment-related purposes
- Fair Work Ombudsman Guidance
- Best practice for managing underperformance includes documented processes
Turn a flag into a fair question
If a figure raises a concern, give the responsible reviewer the specific observation and ask what else needs checking, including the relevant expectations and the employee’s response. That does not mean every dashboard flag should start a formal process.
Keep any performance assessment in the appropriate workplace process, such as the one described in the Fair Work Ombudsman’s best practice guide to managing underperformance. Record the evidence considered, the employee’s response and any later correction. A system score or ranking should not become a lasting judgment merely because the software can store it.
How to Use HR Data Fairly in Performance Discussions
- Identify the observation from the recorde.g., task marked complete, shift missed, leave taken
- Check the source and context of the dataVerify record accuracy, period covered, and whether corrections are pending
- Ask a fair, specific questione.g., 'What was the quality of the work? Did the employee have the tools needed?'
- Gather supporting evidenceReview task requirements, employee feedback, and work allocation changes
- Record decisions and responsesDocument evidence considered and any corrections made
Using System Scores in Performance Judgments: Pros and Cons
- ProsProvides quick visibility into performance trends; supports data-driven discussions
- ConsCan become a lasting judgment without context; may reflect system issues, not individual effort
Share only what the decision needs
A report showing records updated after the reporting cut-off identifies a timing issue under a defined rule. It does not by itself show why updates were late or who was responsible. Give an authorised reviewer the population, period and measure needed to investigate, then gather other relevant evidence separately.
When sharing a report, distinguish the recorded measure from any interpretation. Where the APPs apply, APP 6 allows personal information to be used or disclosed for the purpose for which it was collected, or for a secondary purpose only if an exception applies, so check the purpose before sharing a report beyond its reviewers.
