Access Rights and Storage Standards for Workplace Harassment Investigation Data

Workplace Harassment · Investigation Data Management Guide

Workplace harassment investigation data,
Start by establishing access rights and storage standards.

Access rights and storage standards for workplace harassment investigation materials are not merely matters of organizing files after the investigation concludes, but are core management items that must be established from the initial stage of the investigation. HR personnel must clarify who has access to complaint forms, interview records, supporting documents, investigation reports, and records of protective measures, as well as where the materials will be stored and how long they will be managed after the investigation is completed.

short answer

Allow only necessary personnel to access, and collect and store data only to the extent required for the purpose of the investigation.
The core flow is: defining the scope of data collection → assigning access rights → restricting storage locations → managing viewing and sharing history → identifying final versions → establishing retention periods and destruction criteria → post-access control.

🕒 When will it be applied?

Standards for access rights and storage of workplace harassment investigation data are required in the following situations.
situation
Items to check by the person in charge
Immediately after receiving the report
Storage locations and access designation for report forms, reception records, and initial interview data
Designation of investigator
Distinction in access scope by investigator, HR manager, and reviewer
Interviews with complainants, affected workers, etc.
Verification of confidentiality standards for statement records and requests for protective measures
Interview with the accused
Restriction on access to explanatory materials and investigation questionnaires
Witness interview
Manage witness statements to prevent exposure to other witnesses or parties.
Submission of supporting documents
Verification of the originality and storage location of materials such as messenger messages, emails, recordings, and photos
Request for cooperation from the department head
Share only the minimum information necessary for work coordination
Preparation of investigation results report
Separation of access rights between result reports and raw data
Review of disciplinary and personnel measures
Share with relevant departments only to the extent necessary
After the conclusion of the investigation
Summary of retention period, destruction criteria, and re-access criteria
The management of investigation data is not solely for the sake of the fairness of the investigation. It is also connected to the protection of whistleblowers and victimized workers, the procedural rights of the accused, the protection of witness confidentiality, the protection of personal information, and the prevention of secondary harm within the organization.

🧭 What an HR Manager Should Do

STEP 01

First, classify the types of research data.

You should not share or store all workplace harassment investigation materials at the same level. Since the sensitivity and purpose of each type of material vary, it is advisable to classify the materials first.
Data types
example
Management direction
Received materials
Report form, receipt email, consultation request record
Minimize accessors, preserve original
Interview materials
Interview records of complainants, victimized workers, the accused, and witnesses
File separation by party, viewing restrictions
Supporting documents
Messenger capture, email, photo, recording, document
Maintain originality, no unauthorized modification
Protective measures data
Request for change of work location, paid leave, work adjustment records
Management of the intentions and history of measures taken by affected workers, etc.
Investigation Results Report
Facts, grounds for judgment, proposed measures
Stored separately from original data
Personnel and Disciplinary Data
Disciplinary Committee materials, results of actions, notification documents
Separate management of personnel data access rights
Post-management data
Return support, verification of secondary damage, EAP guidance records
Minimize sensitive information
Classifying data types makes it easier to determine “who can view which data.” For management, reporting only the scope necessary for research summaries and decision-making may be more appropriate than reporting the entire raw data.
STEP 02

Access permissions are restricted based on roles.

It is advisable to set very strict access permissions for workplace harassment investigation data to prevent curiosity or rumors within the organization. You must distinguish between those essential to the investigation and those who require only work cooperation.
role
Accessibility range example
Points to note
investigator
Report, interview records, supporting documents, draft investigation report
Prohibited from use for purposes other than investigation
HR Manager
Investigation progress, protective measures, results report
Minimize sharing detailed statements
Legal and Labor Reviewer
Materials required to identify issues
Provide only the necessary range
Management
Summary materials required for action decisions
Avoid sharing the entire source material
Department Head
Minimum information required for work coordination
Caution regarding the sharing of details of reports and statements
The person reported
Facts to be verified within the scope necessary for clarification
Considering the balance between whistleblower protection and the right to defense
witness
Personal Interview Schedule and Confidentiality Information
Prohibition on sharing other statements or materials
General members
Inaccessible
Preventing the spread of rumors and speculation
Access permissions should be set based on roles rather than names, and permissions must be revoked or changed immediately when the person in charge changes.
STEP 03

Investigation files use a separate storage location.

It is recommended to store research materials in a separate restricted folder to prevent them from mixing with general HR data or team shared files. Uploading them to a general shared drive or saving them in a folder accessible to multiple people may result in unintended viewing.
Confirmation items
Management standards
Storage folder
Create restriction folders by case
Accessors
Minimum personnel including investigators and HR managers
Permission method
Distinction between View, Edit, and Download permissions
filename
Unified based on case number, data type, and date
Final Version Mark
Distinction between draft, review version, and final version
Backup
Manage to prevent arbitrary copies from being created in multiple places
Sharing method
Use restricted links or secure storage instead of email attachments
Delete/Retrieve
Clean up temporary files and unnecessary copies after the investigation is complete
It is best to avoid including unnecessarily provocative expressions or sensitive content in filenames. For example, it is safer to organize files based on case numbers and data types rather than stigmatizing language.
STEP 04

Raw data and result reports are managed separately.

The raw materials collected during the investigation process and the final results report are different in nature. The raw materials may include detailed statements and sensitive evidence, while the results report summarizes the issues of the investigation, confirmed facts, grounds for judgment, and follow-up actions.
division
Contents included
Sharing criteria
raw materials
Report, original interview transcript, screenshot, recording, email
Investigator-centered restriction
Review materials
Summary of Issues, Comparative Table of Facts, Legal and Labor Review Memo
Reviewers only
Result Report
Scope of investigation, confirmed facts, judgment, proposed measures
HR leaders and decision-makers-centered
Notification materials
Summary of results to be provided to the complainant and the respondent
Scope required for each party
Personnel data
Documents related to disciplinary actions, transfers, and protective measures
Personnel authority and person in charge
By separating them in this way, you can reduce the unnecessary spread of personal information and sensitive statements.
STEP 05

Viewing and sharing history is recorded.

It is advisable to manage research data not only by restricting access rights but also by tracking who viewed or shared which materials and when.
In particular, when providing materials to external labor consultants, lawyers, counseling agencies, or commissioned investigators, the purpose and scope of the provision must be recorded.
Management Items
Record example
Reader
HR manager, legal manager, external labor consultant
Viewing date and time
2026.08.10 14:00
Data range
Draft investigation report, interview summary
Purpose of provision
Legal review, review of protective measures, preparation for the disciplinary committee
Provision method
Restricted folder links, encrypted files, face-to-face viewing
Whether to recall
Request to delete copies after review is complete
Confidentiality Guide
Notice on the necessity of confidentiality before providing materials
If research data is sent to multiple people via email attachments, retrieval and management may become difficult later on. If possible, it is safer to allow access based on permissions within a restricted storage environment.
STEP 06

We set retention periods and destruction standards as internal criteria.

It is difficult to determine the retention period for workplace harassment investigation data simply based on the assumption that "keeping it for a long time ensures safety." Retaining data for too short a time may result in a shortage of materials during subsequent disputes or re-investigations, while retaining it for too long increases the risk associated with the storage of personal and sensitive information.
division
Review criteria
Data under investigation
Restricted storage until investigation is completed and follow-up measures are finalized
Final investigation report
Consideration of internal company retention standards and potential for disputes
raw materials
Keep only what is necessary and clean up unnecessary copies.
temporary files
Clean up duplicates and downloaded copies after the investigation is completed
Personnel and Disciplinary Data
Linked to personnel data retention standards
Counseling and psychological support records
Separate from investigation data and protect counseling content separately.
Destruction record
Destruction date, subject materials, and person in charge records
Rather than assuming that the retention period applies uniformly to all companies, it is advisable to determine it through internal company regulations and legal review.
STEP 07

We do not mix counseling records and investigation data.

During the investigation of workplace harassment, EAP counseling, grievance counseling, and interviews with health managers may be conducted. In such cases, care must be taken to ensure that the content of the counseling is not incorporated into the investigation materials as is.
Counseling is a procedure designed to provide psychological support, while an investigation is a procedure to verify the facts. If the two types of data are mixed, trust in the confidentiality of the counseling may be compromised.
division
purpose
Management direction
Research data
Verification of facts, review of protective measures, and follow-up personnel actions
Investigator-centered restricted storage
EAP counseling records
Psychological burden, recovery support
Criteria for the company and investigators not to access personal counseling content
Grievance counseling records
Initial consultation, procedure guidance, confirmation of intent to report
Distinction between conversion to official investigation and scope of records
Health management records
Health and safety support
Restriction on access to health information
Factual data required for the investigation and psychological content emerging from the counseling process must be distinguished. If necessary, the consent of the party involved, legal grounds, and the necessity of the investigation must be verified separately.

📋 Management Sheet Example

The table below is an example of internal management guidelines that can be used when organizing access rights and retention standards for workplace harassment investigation data. The actual items should be adjusted to align with the company's employment rules, grievance handling regulations, personal information protection standards, and personnel data retention standards.
division
Management Items
Record example
Case Information
Case number, date of filing, investigator
2026-001 / 2026.08.10 / HR Manager
Data types
Report, interview record, supporting documents, results report
Interview record
Storage location
Restricted folders, secure storage
HR Restriction Folder
Access permissions
Those who can view
Investigator, HR Manager
Editing permissions
Editable
One investigator
Sharing status
Whether provided to external reviewers
Review by an external labor consultant
Sharing scope
Scope of provided data
Interview Summary, Draft Results Report
Confidentiality Guide
Whether to inform the reader of confidentiality standards
Information completed
Final Version Classification
Draft, Review, Final
Final Report_v1
Storage period
Scheduled storage period based on internal standards
In accordance with internal document retention standards
Destruction criteria
Scheduled time of destruction and person in charge
Review after expiration of retention period
Post-mortem viewing
Criteria for Approval of Re-examination After Investigation Conclusion
HR Manager approval required

✅ Checklist

The checklist below is for internal inspection purposes to verify that access rights and storage standards for workplace harassment investigation materials are being properly managed.
especially Classification of data types, restriction of access rights, designation of storage locations, management of viewing and sharing history is a basic verification item. Among all items If 3 or more are insufficient It is recommended to review the investigation data management standards, personal information protection standards, confidentiality guidelines, and post-investigation access procedures.
division
Confirmation items
check
Data types
Data types were classified, such as reports, interview records, supporting documents, and result reports.
Collection scope
We collected only the data necessary for the purpose of the investigation.
Storage location
A restricted folder or secure storage dedicated to research data was used.
Access permissions
We set it up so that only necessary personnel, such as investigators and HR managers, can access it.
Editing permissions
Editing permissions were restricted to prevent arbitrary modification of the original data.
Sharing scope
The scope of materials to be provided to department heads, management, and external reviewers was limited.
Viewing history
It recorded who viewed and shared which materials and when.
filename
I organized the filenames based on case number, data type, and date.
Final version
I distinguished between the draft, the review version, and the final version.
Separation of raw data
The raw data and result reports were managed separately.
Separation of counseling records
The EAP counseling content and survey data were not mixed.
temporary files
I cleaned up temporary copies of personal PCs, messengers, and email attachments.
Storage period
The retention period was determined in accordance with internal document preservation standards and personal information protection standards.
Destruction criteria
Procedures were established to review destruction or additional storage after the expiration of the retention period.
Post-mortem viewing
Approval criteria were established for cases where re-examination is required after the investigation is completed.

⚠️ Common mistakes

POINT 01

Saving survey data as is to a general HR shared folder

Even if a folder is accessible to the entire HR team, not every member needs to view the investigation materials. It is recommended to create restricted folders by case and minimize the number of people who can access them.
POINT 02

Sharing the entire interview record or supporting materials with the department head

Department heads may need to cooperate with work coordination, but often do not need to review all the details of the report and statement.
POINT 03

Sending research data to multiple people as an email attachment

Attachments leave copies and can be difficult to retrieve. If possible, it is recommended to provide them in a manageable manner, such as through restricted links, secure storage, or in-person viewing.
POINT 04

Mixing raw data and result reports

Since raw materials contain sensitive statements and evidence, it is recommended to provide decision-makers with summaries or result reports when necessary.
POINT 05

Including EAP counseling or grievance counseling content as is in the investigation data

Since counseling and investigation have different purposes, the content of psychological support and data from the investigation of facts must be distinguished.
POINT 06

Leaving the authority intact after the investigation is concluded

Even after the investigation is completed, you must establish criteria for revoking access rights and post-investigation viewing due to changes in the investigator, departmental transfers, or resignations.

💬 When EAP support is needed

The management of access rights and storage of workplace harassment investigation materials is not an area that an EAP can handle. The collection of investigation materials, setting of access rights, retention periods, destruction criteria, notification of investigation results, and review of personnel actions must be conducted in accordance with the company's official investigation procedures and personal information protection standards.
However, during the investigation process, the complainant, victimized employee, accused party, witnesses, managers, and investigators may experience significant psychological burden. If anxiety, sleep problems, difficulty concentrating on work, relationship tension, or the burden of returning to work are significant during the investigation, an EAP may be recommended as a supplementary channel.
division
role
Workplace harassment investigation
Verification of facts, review of protective measures, and follow-up personnel actions
Research data management
Management of access restriction, record retention, confidentiality, and destruction criteria
HR & Grievance Handling Procedures
Report reception, investigation operation, result notification, follow-up inspection
EAP counseling
Psychological burden, anxiety, relationship difficulties, recovery support
Emergency response
In the event of an immediate safety risk, prioritize internal company crisis response procedures and appropriate emergency support channels.
If you require counseling due to psychological burden, anxiety, sleep problems, or relationship difficulties during the workplace harassment investigation process, you may utilize the EAP counseling channel. EAP does not replace the workplace harassment investigation or official company measures; it is a supplementary channel designed to support employees' psychological well-being.
If an immediate safety risk is suspected, do not respond solely with general EAP guidance; instead, you must first identify the company's internal crisis response procedures and appropriate emergency support channels.

❓ Frequently Asked Questions

Q1. Is it acceptable for the entire HR team to view the workplace harassment investigation data?

Even if the data is internal to the HR team, not all HR personnel need to view the investigation materials. It is recommended to restrict access to personnel actually required for the job, such as investigators, HR managers, and necessary reviewers.

Q2. May I share the report details or interview records with the department head?

The department head may need to know some information to coordinate tasks or schedules. However, it is safer to share only the minimum information necessary for cooperation, rather than sharing the entire report, interview records, and supporting documents.

Q3. Do I have to show all the supporting documents to the respondent?

You may provide the accused with information within the scope necessary for verifying the facts and providing clarification. However, it is advisable to determine the scope of material provision by considering the protection of the whistleblower, the confidentiality of witnesses, the protection of personal information, and the possibility of obstructing the investigation.

Q4. What should be the retention period for survey data?

It is difficult to conclude that this period applies uniformly to all workplaces. It is advisable to establish an internal standard by reviewing the company's document retention regulations, personnel data storage standards, potential for legal disputes, and personal information protection standards together.

Q5. Can I access the data again after the investigation is completed?

There may be legitimate needs, such as for follow-up disputes, reinvestigations, responses to relevant authorities, or reviews of personnel actions. However, it is advisable to prevent unauthorized access after the investigation is concluded and to establish criteria for post-investigation viewing, such as requiring approval from the HR manager.

Q6. Should EAP counseling content also be included in the survey data?

In principle, it is recommended to manage EAP counseling content separately from investigation materials. EAP is a supplementary channel for psychological support, and a company reviewing individual counseling content or using it as investigation material can undermine trust. Factual data required for investigations must be verified according to separate procedures and standards.

🎯 Three things to check first

Priority check items
Confirmation details
Access permissions
Is it determined who can view the investigation data and to what extent?
Storage Standards
Are there restricted folders by case, distinctions for final versions, retention periods, and destruction criteria?
Sharing Procedure
Is the scope and history of materials to be provided to department heads, management, and external reviewers managed?

Next step

Survey data management
Design from the initial investigation stage.
Organize your research data into a single management system that covers access rights, storage location, viewing and sharing history, final versions, retention periods, and destruction criteria.
Go to Nudge EAP Implementation Consultation →
This content is intended for general informational purposes. Specific legal matters, labor issues, investigation procedures, personal data protection, record keeping, mental health, and psychological counseling matters may vary depending on the specific workplace situation, the latest laws, and official guidelines; therefore, review by relevant experts or authorities may be required.
Comments5
  • Unknown User4
    조사 종료 후에도 접근권한을 그대로 두는 경우가 있을 것 같은데, 담당자 이동이나 퇴사 시 권한 회수 기준도 같이 정리해야 할 것 같습니다.
  • Unknown User3
    원자료와 결과보고서를 분리해서 관리하라는 부분이 도움이 됐습니다. 의사결정자에게 모든 캡처나 면담 원문을 다 공유하는 방식은 확실히 위험할 수 있겠네요.
  • Unknown User2
    부서장이 업무 조정 때문에 일부 정보를 알아야 할 때, 어디까지 공유하는 게 적절할까요? 신고 내용이나 면담 기록 전체를 공유하지 않는 기준이 필요할 것 같습니다.
    Profile Image
    넛지EAP(관리자)
    Author
    안녕하세요, 넛지EAP입니다.
    
    부서장이 업무 조정 때문에 일부 정보를 알아야 하는 경우에도, 신고 내용이나 면담 기록 전체를 공유하기보다는 조치 실행에 필요한 최소 정보만 전달하는 것이 좋습니다.
    
    예를 들어 “당분간 A와 B의 직접 대면 업무를 줄인다”, “보고라인을 임시로 조정한다”, “같은 회의 참석을 피한다”, “근무 장소나 일정 조정이 필요하다”처럼 부서장이 실제로 조치해야 할 내용 중심으로 안내할 수 있습니다.
    
    반면 구체적인 신고 경위, 진술 내용, 참고인 발언, 조사 판단 전의 사실관계, 개인적인 감정 표현 등은 부서장에게 공유하지 않는 것이 안전합니다. 이런 자료는 HR 또는 조사 담당자가 별도로 보관하고, 부서장에게는 실행해야 할 조치와 주의사항만 전달하는 방식이 적절합니다.
    
    공유할 때는 “조사 및 보호조치 목적 외 사용 금지”, “관련자에게 재공유 금지”, “불이익 조치 금지”도 함께 안내하는 것이 좋습니다.
    
    정리하면, 부서장에게는 업무 조정에 필요한 범위의 조치사항만 공유하고, 신고 내용·면담 기록·진술 원문은 공유하지 않는 기준으로 운영하는 것이 가장 무난합니다.
    
  • Unknown User1
    조사 자료 접근권한은 조사 끝난 뒤 파일 정리할 때 정하는 게 아니라, 접수 직후부터 정해야 한다는 점이 중요해 보입니다.