HR documentation disorder usually builds up over years. It starts with one missing contract, then it turns out half the medical examinations are out of date, personnel files are in three different places, and some employees never had a file set up at all. If a PIP inspection is approaching or you're taking over HR from someone else – this article is for you.
What the risks of HR documentation gaps are
During an inspection, the National Labour Inspectorate reviews every employee's documentation. The most common violations that result in a fine or an order:
- Missing or incomplete personnel files
- No working-time records or inaccurate ones
- Expired medical certificates (employee working without a valid initial or periodic examination)
- No confirmation of BHP health and safety training
- Employment contracts missing required elements or employee signatures
- Failure to maintain the correct division of files into parts A, B, C, D
What is genuinely urgent and what can wait
Not everything can be fixed at once. It's worth knowing what the priorities are – especially if an inspection could happen any day.
- URGENT: expired medical certificates – an employee without a valid certificate cannot legally work; refer them for examination immediately
- URGENT: missing employment contract or unsigned contract – supplement or reconstruct the documentation
- URGENT: no initial BHP training confirmation – an employee without confirmed training should not be performing their work
- IMPORTANT: incomplete personnel files – supplement in order of priority (current employees → former employees)
- CAN WAIT: organising archives from many years ago – if there is no immediate threat of an inspection
How to start sorting things out – step by step
- Step 1: Make a list of all current employees and check whether each one has a file (personnel file)
- Step 2: For each employee, check whether the medical certificate and BHP training confirmation are current
- Step 3: Verify that contracts are signed and contain all required elements
- Step 4: Check whether working-time and leave records are being kept
- Step 5: Draw up a list of gaps with priorities and start filling them in from those that directly affect the legality of work
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What to do about missing documents – and how to reconstruct them
Some documents can be reconstructed: contracts can be re-signed (with a note of the actual start date), personal questionnaires can be completed retrospectively, and BHP training can be carried out. Former employees are trickier – here the most important thing is to preserve the payroll and ZUS registration documents, as these are the basis for issuing the employment certificate and settling contributions.
Electronic files as a solution for the future
If you're organising documentation from scratch, it's worth considering switching to electronic personnel files maintained in a system that meets the legal requirements. This eliminates the problem of lost documents and makes it easier to check completeness. Moving from paper to electronic files requires notifying employees, but is not complicated in itself.
How I can help
I help companies carry out an HR documentation audit, identify gaps and draw up a plan to fill them. When taking over HR from someone else, I always start with such an audit – to know what I'm dealing with. The first conversation and assessment are free.