HR Document Redaction: Protecting Employee Privacy in Personnel Files

HR departments are custodians of some of the most sensitive information in any organization. Personnel files contain Social Security numbers, salary histories, medical information, disciplinary records, performance evaluations, background check results, and personal contact details for every employee.

When any of this information needs to be shared — with managers, auditors, attorneys, government agencies, or the employees themselves — redaction determines what stays protected and what gets disclosed.

This guide covers the scenarios where HR needs redaction, what must be removed, and how to manage the process without overwhelming your team.

When HR Departments Need to Redact Documents

Employment Litigation

Employment lawsuits — discrimination, harassment, wrongful termination, wage disputes — are the most common trigger for HR redaction. During discovery, the company must produce relevant personnel files, emails, policy documents, and investigation records.

These documents invariably contain information about employees who are not parties to the lawsuit. Their personal data must be redacted before production:

Names and identifying information of uninvolved employees
Social Security numbers throughout personnel files
Salary and compensation data of non-relevant employees
Medical information unrelated to the claims
Performance review details of non-parties

Failure to redact properly can expose the company to additional claims from employees whose information was unnecessarily disclosed.

For discovery-specific guidance, see our e-discovery redaction guide.

Internal Investigations

Workplace investigations — harassment complaints, ethics violations, policy breaches — generate documents that contain information about multiple employees. When the investigation results need to be shared with decision-makers or when the complainant requests a copy:

Witness identities may need protection (especially in harassment or whistleblower cases)
Statements from other employees must be redacted to protect their privacy
Personal details unrelated to the investigation should be removed
Prior disciplinary history of other employees mentioned in the investigation should be redacted

Management Access to Personnel Files

Managers frequently request access to employee files — for performance reviews, promotion decisions, restructuring planning, or succession planning. But personnel files contain information managers should not see:

Medical records and accommodation details (ADA-protected)
Salary history of other employees in the file (for comparison purposes)
EEO and demographic data
I-9 documentation and immigration status
Background check results (access often restricted by state law)

Redacting these categories before sharing files with managers protects both the employee and the organization.

Government Audits and Agency Requests

Multiple government agencies may request personnel records:

DOL (Department of Labor): Wage and hour audits, FMLA compliance reviews
EEOC: Discrimination charge investigations
OSHA: Workplace safety investigations
IRS: Payroll tax audits
State agencies: Workers' compensation audits, unemployment claims

Each request has a specific scope. Information outside that scope should be redacted. An EEOC charge investigation about one employee does not entitle the agency to unredacted files of every employee in the department.

Employee Self-Access Requests

Many states give employees the right to inspect their own personnel files. Under CCPA/CPRA, California employees can request access to all personal information the employer holds about them.

When providing file access, redact:

Reference check notes from the hiring process (where the referrer has an expectation of confidentiality)
Manager-to-manager communications about the employee that include information about other employees
Investigation materials involving other employees
Salary information of other employees that appears in comparison documents

Mergers and Acquisitions

During due diligence, acquirers request employee data to assess workforce composition, compensation structures, and potential liabilities. Before sharing:

Redact individual SSNs and financial account details
Aggregate salary data rather than sharing individual records where possible
Remove medical and disability information
Redact background check results
Protect immigration documentation details

What to Redact from HR Documents

Personnel Files

Document	What to Redact
Job application	SSN, date of birth, driver's license (if not job-relevant)
Offer letter	Other employees' salary info (if referenced), SSN
I-9 form	Document numbers, SSN (when sharing outside I-9 compliance purposes)
W-4/Tax forms	SSN, filing status, personal allowances
Direct deposit forms	Bank account numbers, routing numbers
Benefits enrollment	Dependent SSNs, dependent medical information
Performance reviews	Other employees' names (if referenced comparatively), salary data
Disciplinary records	Witness names (when confidentiality is appropriate), other employees' information
Medical/FMLA records	Keep separate from personnel file; redact when sharing with non-medical staff
Background check	Criminal history details (where restricted by state law), credit information

Investigation Files

Names and contact information of witnesses (when anonymity is warranted)
Statements by other employees (redact names and identifying details)
Personal information of the accused (when sharing with the complainant, depending on organization policy)
Unrelated disciplinary history referenced in the file

Compensation Documents

Individual salary figures of other employees
Bonus amounts for specific individuals
Stock/equity grant details for specific individuals
Salary survey data that identifies participants

Legal Frameworks Governing HR Redaction

Federal Laws

ADA (Americans with Disabilities Act): Medical information must be kept in separate, confidential files and shared only with those who have a legitimate need to know. When personnel files reference medical accommodations, that information must be redacted for most recipients.

HIPAA: Applies to employer-sponsored health plans. Medical information from health plan administration must be protected. While HIPAA does not generally apply to employment records, the information in those records may still be protected by ADA, state privacy laws, or other regulations.

GINA (Genetic Information Nondiscrimination Act): Genetic information, including family medical history, must be treated as confidential and maintained in separate files. Any genetic information in personnel files must be redacted.

Fair Credit Reporting Act (FCRA): Background check results obtained through consumer reporting agencies have specific use limitations and confidentiality requirements.

State Laws

State privacy laws add significant obligations:

California (CCPA/CPRA): Employees have rights to access, delete, and limit the use of their personal information. Responding to these requests may require redaction of other employees' data in shared documents.
Illinois (BIPA): Biometric information (fingerprints, facial recognition data) is subject to strict consent and protection requirements.
New York, Illinois, and others: Personnel file access laws specify what employees can and cannot see in their own files.
Ban-the-box laws: Restrict when and how criminal history information can be used, affecting what should be redacted from files shared with hiring managers.

For a broader overview of privacy compliance, see our data privacy compliance guide.

Building an HR Redaction Workflow

Assess Your Current State

Audit your current practices:

How are personnel file requests currently handled?
Who performs redaction, and what tools do they use?
How long does it take to fulfill a records request?
Have there been instances of accidental over-disclosure?

Implement Proper Tools

Stop using: Markers on printed copies, black boxes in Word/PDF editors, white-out tape on scanned documents. These methods do not actually remove the data from digital documents.

Start using: Dedicated redaction software that permanently removes information from the document structure. AI-powered tools automatically detect SSNs, names, dates of birth, account numbers, and other PII — reducing the risk of human error.

Create Category-Based Templates

Define standard redaction templates for common scenarios:

Litigation production template: Remove SSNs, non-party names, medical information, salary data of non-parties
Manager access template: Remove SSNs, medical records, I-9 details, EEO data, background check details
Employee self-access template: Remove other employees' information, confidential reference notes
Regulatory audit template: Remove information outside the audit scope; retain information relevant to the specific compliance area

Establish Approval Workflows

Define who approves redaction decisions:

Routine requests (manager file access): HR generalist redacts, HR manager approves
Legal discovery: Employment counsel directs, paralegal or HR redacts, counsel reviews
Regulatory requests: Legal department coordinates, HR provides files, legal reviews redaction

Document Everything

Maintain records of:

What was requested
What was provided
What was redacted and why
Who performed and approved the redaction
When the redacted documents were delivered

This documentation protects the organization if redaction decisions are ever challenged.

Frequently Asked Questions

What employee information must HR redact from personnel files?

The specific items depend on who is receiving the file and why. Common redaction targets include SSNs, bank account numbers, medical information, compensation data of other employees, background check results, and personal contact information not relevant to the disclosure purpose.

How does HR handle redaction for employment lawsuits?

Work with employment counsel to identify responsive documents, determine the scope of required production, and identify information that must be redacted (non-party PII, privileged communications, irrelevant confidential data). Use AI-powered redaction tools to detect PII across all documents, then have counsel review before production.

Should medical information be in personnel files?

No. Under ADA, medical information should be maintained in separate, confidential files with access limited to those with a legitimate need to know. If medical information appears in the general personnel file, it should be redacted before the file is shared with anyone who does not need medical access.

How long does HR document redaction take?

Manual redaction of a typical personnel file (30-50 pages) takes 30-60 minutes. AI-powered tools reduce this to 3-5 minutes by automatically detecting sensitive data types. For litigation discovery involving hundreds of files, the time savings are substantial.

What tools should HR use for redaction?

Purpose-built redaction software with AI detection. AI-Redact is SOC 2 certified and detects 40+ PII types including SSNs, names, dates of birth, account numbers, and medical terms. Never use PDF editors, highlights, or drawing tools — these do not remove the data.