1. All employee files, regardless of their format and how they are maintained, are the property of this Company.  All employee files and the information contained in employee files are confidential.  Access to any employee’s file and the information contained in the file is strictly prohibited except as described in this policy.

       2. Access to any employee’s file and information is limited to the employee and to such other company personnel whose responsibilities require access.  Such access is limited to only such uses of the file and information as are required to fulfill the purpose of access.

       3. Access to an employee’s file and information will also be granted to any person identified in a written authorization for access and/or disclosure signed by the employee.  Health and medical information about an employee will not be released except through a properly signed authorization form that meets the requirements of the Health Insurance Portability and Accountability Act (HIPAA).  Access to an employee’s file and information, including health information, will also be made available as required by a court order or as otherwise required by law.

       4.  A current employee has complete access to everything in his/her own file(s).  The conditions under which an employee may view this information are:

              (a)        The employee must make a written request to see his or her own file;

             (b)        The employee’s written request can be to view all information in any file or specific information identified in the request;

              (c)          The information that must be contained in this written request are the employee’s name, any other personal identifiers unique to the employee, such as an identification number, and brief statement of whether the employee desires to see specific information or all information;

              (d)          This request is to be made to the employee’s supervisor or to any other person who can arrange for the employee to view his/her file as requested; 

              (e)          The employee may view the file in a location set aside for this purpose during normal business hours;

              (f)         While viewing the file, the employee may make notes, have photocopies made of anything in the file (requested photocopies will be made by someone other than the employee), but the employee may not add anything to the file or remove anything from the file, nor may the employee have anyone accompany him or her except for the employee’s spouse or immediate family member, attorney, personal representative or such other person as necessary to assist the employee in viewing and understanding the contents of the file.  The employee will not be interfered with while viewing his or her file, but we may choose to have a company representative present as the file is reviewed by the employee.

         5. A request for access to a file which is the subject of or relevant to any actual or potential legal claim may be denied except pursuant to court order, subpoena or as otherwise required by law.