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Is the location of personnel documents relevant in determining whether they need to be disclosed when someone requests their “personnel file”?

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Is the location of personnel documents relevant in determining whether they need to be disclosed when someone requests their “personnel file”?

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No. The term personnel record is defined by law as explained above. We cannot exempt a document from disclosure merely by not placing it in a person’s department or central University personnel file. If a document falls within the definition of “personnel record”, which is quite broad, then it must be disclosed to the employee upon request, regardless of its physical location.

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