The digital 201 file: what to keep in employee records and how to manage them

In Philippine HR, the 201 file is the complete personnel file of an employee: the documents and records created from application to separation. A well-kept 201 file lets HR prove compliance, answer employee questions, support due process in disciplinary cases and produce records quickly when DOLE, the BIR, SSS or a court asks. For companies with many branches, moving 201 files from paper folders into a digital HRIS is one of the fastest ways to reduce risk.

201 file checklist

Pre-employment and hiring

• Application form and résumé
• Interview and assessment records
• Job offer and signed employment contract
• Pre-employment medical results (handled as sensitive personal information)
• Clearances required by your policy, such as NBI clearance
• Birth certificate and, where relevant, marriage certificate and dependents' documents

Government and tax

• SSS, PhilHealth, Pag-IBIG and TIN records
• BIR registration forms and previous employer's BIR Form 2316

Employment history

• Job description and position history
• Probationary evaluation and regularization notice
• Salary change approvals and promotion or transfer memos
• Performance appraisals (performance appraisal guide)
• Training records and certificates
• Leave records and approvals

Discipline and notices

• Notices to explain, employee responses, hearing minutes and decisions
• Commendations and awards

Separation

• Resignation letter or termination notices
• Clearance form and asset return records (offboarding guide)
• Final pay computation and acknowledgment
• Certificate of employment issued

Retention and access

DOLE rules require employers to keep employment records for at least three years from the last entry, and other agencies have their own retention rules for tax and contribution records. Many companies keep 201 files longer for defense against claims. Set a written retention schedule with your legal adviser that covers each document type.

Under the Data Privacy Act (RA 10173), employee records contain personal and sensitive personal information. That means:

• Collect only what you need for a legitimate purpose
• Limit access to people who need it, by role
• Protect records with security measures and keep access logs
• Dispose of records securely when the retention period ends

See the Data Privacy Act and business systems.

Problems with paper 201 files

• Folders are stored at branches, so head office cannot see them
• Documents go missing during transfers between branches or companies
• Anyone with cabinet access can read sensitive information
• There is no record of who viewed or changed a file
• Producing records for an audit or case takes days

Moving to digital 201 files

1. Define the document types and which are mandatory for each employee group.
2. Set up the employee record in your HRIS with the organization structure and role-based access.
3. Scan and attach existing documents, starting with active employees, using consistent naming.
4. Run a completeness report: which employees are missing which mandatory documents.
5. Make new documents digital by default: contracts, notices and approvals created in the system.
6. Decide what to do with paper originals under your retention policy.

What a good digital employee record looks like

• One record per employee across all companies in the group, with movements history
• Documents attached to the record, categorized and searchable
• Effective-dated changes for position, salary and branch
• Access by role, and logs of who viewed or changed what
• Reports on missing documents, expiring contracts and pending regularizations

Cirquolus HRIS keeps active and inactive employee records, notices and transitions with page access and permission groups. The recruitment module includes a document explorer for hiring documents, and Vault offers personal, team and company file storage.

Frequently asked questions

What is a 201 file in the Philippines?

It is the personnel file of an employee containing hiring, government, employment history, discipline and separation records.

How long should 201 files be kept?

DOLE requires employment records to be kept for at least three years from the last entry. Other agencies and legal considerations may justify longer retention; set a written policy with your adviser.

Can employees request a copy of their 201 file?

Under the Data Privacy Act, employees have the right to access personal data the employer holds about them, subject to the law's conditions. Have a process for handling such requests.

Is a scanned 201 file valid?

Electronic documents are generally recognized under the E-Commerce Act, but keep originals of documents that may be needed in legal proceedings according to your adviser's guidance.