SSS · HR Policy & Disciplinary Framework

How should we record disciplinary penalties in the personnel file?

Disciplinary penalties should be kept in an orderly way in the employee’s personnel file rather than in scattered emails or verbal warnings. The Labour Law (No. 4857) obliges the employer t…

Updated · July 20261 min readCategory · HR Policy & Disciplinary Framework
Short answer

In the personnel file, with the defence statement and written minutes attached, in line with personal data retention periods. Scattered emails are not a file.

Disciplinary penalties should be kept in an orderly way in the employee’s personnel file rather than in scattered emails or verbal warnings. The Labour Law (No. 4857) obliges the employer to keep a personnel file, and every penalty should be filed in date order together with the conduct it rests on, the employee’s written defence and, where they exist, the minutes and the witness statements. Citing the corresponding provision of the disciplinary rules for the sanction applied matters for evidencing both proportionality and equal treatment.

Because these records are personal data, they have to be kept in a way that is limited to their purpose, restricted in access and consistent with the defined retention periods, as the Personal Data Protection Law (No. 6698) requires. A well-kept record is the principal evidence that the process was followed properly in any later dismissal for valid reason or reinstatement claim, so completeness matters as much as form.

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