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Access Rights and Storage Standards for Workplace Harassment Investigation Data
2026.08.10 09:49
Access rights and storage standards for workplace harassment investigation materials are not merely a matter of organizing files after the investigation concludes, but rather a core management item 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
It is recommended to restrict access to workplace harassment investigation data to only the necessary personnel and to collect and store it only to the extent required for the purpose of the investigation.
Investigation materials may contain sensitive information, such as statements from complainants, affected employees, the accused, and witnesses, as well as messenger screenshots, emails, audio recordings, attendance data, performance evaluation data, and mentions regarding sick leave or counseling. Therefore, it is advisable to avoid storing these materials in locations with wide access, such as general shared folders, departmental shared drives, or group messenger attachments.
Furthermore, you must distinguish between those who need access, such as investigators, HR managers, and legal and labor reviewers, and those who are simply curious about the situation. Being a department head or manager does not mean you need to review the entire investigation data.
The key point is Defining data collection scope → Assigning access rights → Restricting storage locations → Managing viewing and sharing history → Identifying final versions → Establishing retention periods and destruction criteria → Post-retrieval access control It is to create a flow.
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 HR Managers Should Do
1. First, classify the types of survey 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 what data.” For example, for management, it may be more appropriate to report only the scope necessary for decision-making and research summaries, rather than the entire raw data.
2. 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 requiring only work cooperation. In particular, care must be taken to ensure that the entire investigation data is not shared with department heads, direct supervisors, team members, or witnesses.
| 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.
3. 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.
When determining the storage location, check the following items.
| 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, Bullying_Perpetrator_Hong Gil-dong_Statement Rather than using stigmatizing expressions like 2026-001_Interview Record_Respondent_20260810 Organizing based on case numbers and data types, as shown, is a safe method.
4. 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.
Therefore, rather than distributing the entire raw data to multiple decision-makers, it is recommended to share results reports or summary materials when necessary.
| 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.
5. Records viewing and sharing history.
It is advisable to not only restrict access to research materials but also to manage who viewed or shared what materials and when.
In particular, when providing materials to external labor consultants, attorneys, counseling agencies, or commissioned investigators, you must record the purpose and scope of the provision. Within the company as well, it is advisable to manage the moments when materials are transferred, such as reporting to management, providing materials to HR committees, or requesting cooperation from department heads.
| 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.
6. Retention periods and destruction standards are established 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.
Therefore, it is advisable to determine the retention period by reviewing internal company document retention regulations, employment rules, personnel data storage standards, potential for legal disputes, and personal information processing standards together.
| 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.
7. 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 not accessing 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 table 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 folder, 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 These are basic verification items. If even one of these items is not organized, it is recommended to supplement it first rather than considering the management of survey data complete.
Among all items If 3 or more are insufficient It is recommended to review investigation data management standards, personal information protection standards, confidentiality guidelines, and post-inquiry procedures, rather than simply moving the file location.
| 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
The first mistake is saving investigation materials directly in a general HR shared folder. Even if the folder is accessible to the entire HR team, not every member needs to view the materials. It is recommended to create restricted folders for each case and minimize access.
The second mistake is sharing the entire interview record or supporting materials with the department head. While the department head may need to cooperate with work coordination, there are often cases where they do not need to review all the details of the report and statement.
The third mistake is sending research materials to multiple people as email attachments. 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.
The fourth mistake is mixing raw data with result reports. Since raw data contains sensitive statements and evidence, it is best to provide decision-makers with a focus on summaries or result reports when necessary.
The fifth mistake is including EAP counseling or grievance counseling content directly as investigation data. Since counseling and investigation have different purposes, psychological support content and factual investigation data must be distinguished.
The sixth mistake is leaving permissions intact after an investigation is concluded. Even after the investigation ends, you must revoke permissions and establish post-investigation access criteria due to changes in the investigator, departmental transfers, or resignations.
If 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.
In particular, EAP counseling records and investigation data must be distinguished.
| 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 Route | Response to suicide/self-harm suggestions, risk of violence, and immediate safety risks |
EAP guidance text can be used as follows.
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.
However, in cases involving suggestions of suicide or self-harm, immediate safety risks, or risks of violence, do not respond solely with general EAP guidance; instead, you must first check emergency channels such as 119, 112, or the suicide prevention hotline 109.
Related Posts
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Comprehensive Guide to Workplace Harassment Reporting Procedures and Prevention Education
-
Guidelines for Operating Counseling Support After Reporting Workplace Harassment
-
What should HR do first when a workplace harassment report is received?
-
Checklist for Preventing Secondary Victimization During Workplace Harassment Investigations
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 agencies, 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 verifying or using individual counseling content as investigation material can undermine trust. Factual data required for investigations must be verified according to separate procedures and standards.
Next step
The access rights and storage standards for workplace harassment investigation materials are not merely tasks for organizing files after the investigation; rather, they are procedures that must be designed from the initial stages of the investigation to ensure fairness, protect confidentiality, and prevent secondary harm.
It is recommended that HR managers first check the following three points.
| 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? |
If you wish to streamline workplace harassment investigation procedures, data access rights, confidentiality standards, and EAP counseling coordination at the organizational level, review the operational methods suitable for your organization through a Nudge EAP implementation consultation.
👉 Go to Nudge EAP Implementation Consultation →
Source and Information
-
Ministry of Employment and Labor, Workplace Harassment Judgment and Prevention/Response Manual
-
Korea Labor Welfare Network, Introduction to the Employee Assistance Program (EAP)
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 workplace situation, the latest laws, and official guidelines; therefore, review by relevant experts or agencies may be necessary. In cases involving indications of suicide or self-harm, immediate safety risks, or risks of violence, do not respond solely with general EAP guidance; instead, prioritize checking emergency channels such as 119, 112, or the Suicide Prevention Hotline 109.
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