4.2 Handling of Employee and Volunteer Personnel Records

Published

March 22, 2018

Policy and Procedure 4.2 - Handling of Employee and Volunteer Personal Records

  1. Purpose

The purpose of this policy is to ensure that each ESIP employee and volunteer exercises reasonable efforts to safeguard the confidentiality, security and privacy of employment records and the personal information of its former and current employees and volunteers.

  1. Definitions of Information and Data Relating to this Policy

Sensitive personal information means the following, when combined with any additional information sufficient to identify an individual (including name, address or telephone number):

Employment records means the personnel records of employees maintained for payroll, tax reporting, health coverage, and other employment activities (e.g., airline mileage club membership).

  1. Handling of Employee and Volunteer Records Policy

This policy pertains to an employee or volunteer's personal information, mostly including sensitive personal information as defined above. Such information is considered to be confidential and cannot be released, except as permitted by this policy, without authorization.

ESIP-assigned information, which may include office telephone numbers, e-mail addresses, work addresses, is not considered to be personal information. ESIP retains the right to communicate and distribute such information as it deems necessary to conduct its operations.

Access to employment records or personal information regarding an employee is limited to the current employee and, for official business purposes with exceptions authorized by the ESIP Executive Director. Employment records and personal information may be disclosed to third parties only:

(1) as necessary to enable ESIP agents to implement ESIP’s routine employment, employment verification and payroll; provided that: (i) the ESIP Executive Director has approved the disclosure, and (ii) the ESIP Executive Director has confirmed that the recipient of such information is legally obligated to protect the privacy and security of such information.

(2) with the individual's consent, or

(3) pursuant to a legal authorization, such as a subpoena, court order or official written request from a state or federal investigatory agency.

  1. Employee and Volunteer Personal Records Procedure

Release of personal information. Employment records and the personal information of employees and volunteer, including an individual's sensitive personal information, may not be accessed or released, except as permitted by the handling of employee and volunteer records policy.

Disposal of employee and volunteer personal records shall comply with ESIP Policy and Procedure 1-6: Record Maintenance.

Employment verification and income verification for current or former employees will be provided by ESIP and/or its agents to banks or other to external parties only upon the individual's request or authorization. Similarly, employment references will be provided by ESIP to external parties only upon the individual's request or authorization and should represent the experience of the person providing the reference rather than that of ESIP as a whole.

ESIP’s agents may verify employment and income, upon employee request.  Verification will include the following information: only a) appointment status, b) job title, and c) dates of employment.

This Policy was approved by the Board of Directors of ESIP on October 17, 2017.