The situation
The categories of personnel records the company holds
A Wrocław logistics group is moving its personnel files to a new HR system. The Polish archive holds files going back to 1998, and the German subsidiary in Dresden has boxes of applications and payroll records. The HR lead has to decide what migrates, what is destroyed and what stays on paper, and write it down as a retention schedule.
The data protection officer wants deletion dates for everything. Payroll wants nothing deleted. The law sits between them: a Polish rule with transitional cases, and in Germany a set of periods drawn from tax, social security and civil law. Mapping each record type to its period is the job.
What the research has to settle
The rules behind the answer
- Poland: the period depends on the hire date
- For employees hired since 2019, Polish law sets a ten-year retention period for employee records, counted from the end of the year in which the employment ended. Longer periods can still apply to people hired earlier, depending on the reports the employer filed with the social insurance institution.
- Germany: several periods, no single rule
- German law has no single retention period for personnel files. Payroll records follow tax and commercial-law periods, and limitation periods for claims set how long other records are worth keeping.
- Storage limitation applies throughout
- Under the GDPR, personal data may be kept only as long as its purpose requires. When the statutory period ends and no other purpose applies, the records should be deleted.
- Applicants are a separate category
- Records of unsuccessful applicants are usually kept only while a discrimination claim can still be brought, then deleted. The research establishes the claim period in each country.
How it runs in azta
From the question to the document
The question, as you would type it
Polish employer: how long must we keep the personnel file of an employee hired in 2012 and dismissed in 2021, and of one hired in 2020? In Germany: how long must we keep payroll records and the files of rejected applicants?
You start with
The categories of personnel records the company holds
- 01
List the record types
Give the categories: personnel files, payroll, time records, applications, health checks. azta searches the Polish and German labour, tax and social security legislation and the GDPR.
Cited research· Free - 02
Check the transitional rules
For older Polish files, open the provisions in the reader and ask about the law at the date of hire.
Atlas statute reader - 03
Draft the schedule
Ask for a table: record type, period, start of the period, action at the end and the provision. Edit it in Canvas.
Canvas · Ask azta· Pro - 04
Export for the DPO
Export to Word for the data protection officer’s approval and the system configuration.
Word export· Pro You send
A retention schedule: each record type, its period, when it starts and what happens after
What you get
A retention schedule: each record type, its period, when it starts and what happens after
Retention schedule · draft
Personnel records: retention by category, Poland and Germany
Poland, employees hired since 1 January 2019. Keep the personnel file and payroll records for ten years from the end of the calendar year in which employment ended, then delete them.
Poland, employees hired before 2019. The period depends on whether the employer filed the information reports for that employee with the social insurance institution. The affected files are listed in Annex 1 with the status of each.
Germany. Payroll records are kept for the period set in tax law, shown in Annex 2 with the provision. Files of unsuccessful applicants are deleted once the claim period has passed. Other personnel records are reviewed each year and deleted when no purpose remains.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
21 minutes a month
At €80 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €1,728
- More retention schedule reviews a quarter
- 0.8
- Return on Pro
- 5.3×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
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Book a demoSources azta searches here
- Dziennik Ustaw
- Gesetze im Internet
- EUR-Lex · Curia
What stays with you
- Classifying each record into the right category.
- Configuring deletion in the HR system.
- The DPO’s approval of the schedule.
Frequently asked questions
- Can I see the rule as it stood when someone was hired?
- Yes. Ask about the law at a past date and the reader shows the version in force then.
- Does azta delete anything?
- No. It researches and drafts the schedule. Deletion is configured in your own systems.
- Does it cover data protection authority guidance?
- azta holds the GDPR, EDPB material and national legislation, but not every national authority’s guidance. The source register lists what is included.
