[Personal Information Protection Act] HR Grievance Counseling Record Management Standards

From the perspective of the Personal Information Protection Act, the purpose of collection, access rights, retention period, and whether to provide records to third parties must first be clearly defined for HR grievance counseling records. Counseling records accumulated without management standards do not protect the organization but become a new risk.

The moment you view consultation records as "internal memos," the risk begins.

HR grievance counseling is an important channel for early detection and support of organizational conflicts. However, problems arise if there are no clear standards for the method of keeping records.

The circumstances of the counseling request, the details of the grievance, psychological difficulties, and interpersonal conflicts may be directly related to the private lives of employees. The Personal Information Protection Act classifies information related to health and privacy as sensitive information, and personal information processors must take measures to ensure the safety of such information to prevent leakage, alteration, or damage (Articles 23 and 29 of the Personal Information Protection Act).

The point at which "memos for management convenience" become information subject to legal obligations is faster than expected.

Situations where grievance records turn into organizational risk

Risk situation	Possible problems	HR Inspection Criteria
Multiple staff members can view the consultation details	Concerns over invasion of privacy and secondary harm	Minimize access permissions
No fixed storage period	Unnecessary long-term storage	Setting standards for storage and destruction
Consultation details are forwarded to the manager	Concerns about disadvantage or retaliation	Prior control of sharing scope
EAP usage status is exposed	Leads to avoidance of using the system	Anonymous and tabulation standards operation
Mixing of report records and consultation records	Confusion between investigation purpose and support purpose	Separation of records by purpose

4 Principles to Organize Before Creating a Record

First, clarify the purpose of the collection.
"Grievance counseling support," "Organizational risk reception," "Investigation proceedings," and "EAP integration" have different purposes. Since the purposes differ, access rights and retention standards also differ. If they are not designed separately from the beginning, it will be difficult to organize them later.

Second, record only the necessary information.
It is safer to limit your notes to the scope necessary for practical work, such as the date and time of receipt, requests, required protective measures, and whether follow-up contact will be made, rather than expressing emotions or making speculative notes.

Third, separate access permissions by role.
A structure where all HR members can access consultation records carries a high risk. It is necessary to divide authority by role, assigning roles to the person in charge, the approver, and legal and labor consultants.

Fourth, separate EAP records and internal HR records.
To ensure utilization rates, employees must be clearly informed of the principle that EAP counseling content is not shared with the company on an individual basis. It is common practice for organizations to design systems that protect individual counseling details while only monitoring operational status based on anonymity and aggregate standards.

Checklist for organizations to have in place right now

We have organized it according to practical standards so that it can be used for immediate inspection.

The purpose of collecting grievance counseling records was documented.
Counseling records and reporting/investigation records were separated.
Minimized the number of authorized users to view consultation content.
Defined the scope of information that can be shared with the administrator.
We informed employees of the principle of non-disclosure regarding EAP usage and counseling content.
The storage period and destruction criteria were established.
Items potentially containing sensitive information were checked separately.
We established a response manager and reporting line in the event of an information leak.

If consultation information was shared inappropriately: 72-hour response flow

Initial response when a problem occurs determines future organizational trust.

hour	Response phase	Checklist
0~24 hours	Blocking access to records	Restricted access to unauthorized personnel, file sharing suspended
Within 24 hours	Verification of facts	Check what information was shared with whom.
24~48 hours	Review of potential damage	Verification of disadvantages to the party involved, secondary harm, and the existence of rumors within the organization
48~72 hours	Follow-up measures	Access permission reset, guidance text supplementation, EAP support guidance
After 72 hours	Prevention of recurrence	Maintenance of record forms, retention standards, and personnel training

If counseling information is shared inappropriately, the individual may experience psychological distress. While EAP does not replace legal action, it is necessary at this stage to guide employees to external support channels where they can manage their anxiety and stress.

Without record management standards, the system itself becomes a risk.

Grievance records are the starting point for organizational risk response, but without management standards, they can become another risk. If you are curious about EAP counseling confidentiality standards and internal record management methods, please check below.

👉 Check EAP counseling confidentiality standards →
👉 View HR response standards after sensitive organizational issues →

This content is for general informational purposes only; for specific matters, we recommend consulting with experts in personal information protection, labor relations, or EAP.
Source: Article 23 (Restriction on Processing of Sensitive Information), Article 29 (Duty to Take Safety Measures) of the Personal Information Protection Act
Written by: Nudge EAP Content Team

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