HR Record Retention Requirements

POLAND

DOCUMENTS

RETENTION PERIOD
(minimum and/or maximum)

BEGINNING OF  RETENTION PERIOD

LEGAL REFERENCE

EMPLOYMENT RECORDS

Contracts (new hire agreements, severance, etc.)

Dependent on date of hire:*
- After January 1, 2019:  Minimum 10 years

- Between January 1999 - December 2018: Minimum 50 years, or shortened minimum of 10 years if submit information report to Social Security Institution (starting from the end of calendar year in which report was submitted)

- Before 1999: Minimum 50 years

From end of calendar year after employee's date of termination

Act on Amendment of Some Acts in Connection with Shortening the Period of Storage of Employee Files and their Electronicisation (2018)

*Effective January 1, 2019

Time records (work hours, rest periods, vacation /sick/holiday, etc.)

See above

See above

See above

Performance records (performance reviews, promotions/demotions, licenses/certifications, investigations, disciplinary actions, etc.)

See above

See above

See above

Data and personnel files

See above

See above

See above

Government verification records (work papers, immigration, eligibility to work, etc.)

See above

See above

See above

Collective bargaining/union

Maximum: Only retain personal data as long as necessary for purpose.

From creation

Best practice based on GDPR

Background checks and drug tests

Where legally allowed, retain only as long as necessary to complete hiring process

From creation

Best practice based on GDPR

Acknowledgements, policy agreements and required notices

Maximum: Only retain personal data as long as necessary for purpose.

From creation

Best practice based on GDPR

Recruitment (interview notes, resumes/CVs, reference checks, etc.)

Applicants who are not hired: Only retain until conclusion of hiring process

Applicants who are hired:  Recruitment records are part of employee files (Follow schedule listed in "Contracts" section, above).*

From creation

Best practice based on GDPR

Act on Amendment of Some Acts in Connection with Shortening the Period of Storage of Employee Files and their Electronicisation (2018) - *Effective January 1, 2019

Tracking/recordings (biometric, geo-location, online tracking, camera recordings, etc.)

Camera and other monitoring (for allowed purposes): Maximum 3 months (may be extended in the event of legal proceedings). Employees must receive notice in advance.

From creation of recording

Act on the Protection of Personal Data, Ch. 12, Art. 111 (2018)

BENEFIT/PENSION/EQUITY RECORDS

Benefits (plan documents, enrollment records)

Dependent on date of hire:*
- After January 1, 2019:  Minimum 10 years

- Between January 1999 - December 2018: Minimum 50 years, or shortened minimum of 10 years if submit information report to Social Security Institution (starting from the end of calendar year in which report was submitted)

- Before 1999: Minimum 50 years

From end of calendar year after employee's date of termination

Act on Amendment of Some Acts in Connection with Shortening the Period of Storage of Employee Files and their Electronicisation (2018)

*Effective January 1, 2019

Pension records

See above

See above

See above

Equity records

Minimum: during the existence of the company and 5 years after its liquidation/termination

From creation of recording

Act on National Archiving System and Archives

PAYROLL/WAGE/TAX RECORDS

Payroll and wage data (payslips, etc.)

Dependent on date of hire:*
- After January 1, 2019:  Minimum 10 years

- Between January 1999 - December 2018: Minimum 50 years, or shortened minimum of 10 years if submit information report to Social Security Institution (starting from the end of calendar year in which report was submitted)

- Before 1999: Minimum 50 years

From end of calendar year after employee's date of termination

Act on Amendment of Some Acts in Connection with Shortening the Period of Storage of Employee Files and their Electronicisation (2018)

*Effective January 1, 2019

Tax records

Minimum: 5 years

From end of calendar year to which the records relate

Act of 29 September 1994 on Accounting, Art. 74

MEDICAL/SAFETY/LEAVE RECORDS

Leave (family, medical, etc.)

Dependent on date of hire:*
- After January 1, 2019:  Minimum 10 years

- Between January 1999 - December 2018: Minimum 50 years, or shortened minimum of 10 years if submit information report to Social Security Institution (starting from the end of calendar year in which report was submitted)

- Before 1999: Minimum 50 years

From end of calendar year after employee's date of termination

Act on Amendment of Some Acts in Connection with Shortening the Period of Storage of Employee Files and their Electronicisation (2018)

*Effective January 1, 2019

Injury and illness incident reports

Accident reports and related records: Minimum 10 years

From incident

The Labor Code, Chapter VII, Article 234

Medical records

See "Leave" section, above

See "Leave" section, above

See "Leave" section, above

Hazardous material and other exposure records

Records relating to radiation exposure: Category A workers (who may be exposed to a radiation dose exceeding 1 mSv in 1 year or  an equivalent dose exceeding 1/20th of the dose limits for eye lense, skin and extremities)  - Minimum: until employee reaches ago of 75 years or, 30 years from last date of exposure

From termination of work in exposure conditions

Atomic Energy Act (2000)