Agencies should have management controls to ensure personnel records: adequately document human resource management operations; are accurate and timely; are protected against loss or unauthorized alteration; document the employment history of individuals employed by the Federal Government; can be located when necessary; are retained and disposed of as required by General Records Schedules 1.; and secured against unauthorized access. For example, paper or microfiche/ microfilmed personnel records subject to the Privacy Act should be stored in locked metal file cabinets or in a secured room. Access to electronic records are limited to authorized users through use of logins, passwords, access codes and entry logs. 5 CFR 293.106,107,108 provide additional guidance and requirements. Prior to transfer of a Personnel Folder (whether in a paper or electronic format) to an agency under OPM’s recordkeeping authority, agencies must remove or conceal all Social Security Numbers (SSNs) and other personally identifying information belonging to someone other than the subject that are displayed on records in the Personnel Folder (i.e., lists covering more than one employee in a personnel action) and provide a copy to the employee of the changed record The last employing (losing) agency will provide access to the electronic folder in an appropriate electronic format designated by the gaining agency or provide a paper format if the electronic systems are not compatible or if the gaining agency is operating in a paper environment. The losing agency, after completion of a transfer of an electronic personnel folder, must disable its access to the electronic version of the personnel folder to ensure it complies with the requirements of regulations implementing the Privacy Act at 5 CFR 297.401.

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