FAQs for GRS 2.3, Employee Relations Records
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QUESTION RELATED TO GRS 2.3, ITEM 060
1. How should agencies interpret the disposition instruction found in item 060: “Destroy no sooner than 4 years but no later than 7 years after case is closed”?
The Office of Personnel Management (OPM) has determined that each agency should select a period between 4 and 7 years as the disposition time frame for all instances of these records, and note it in agency manuals or other official records management documents. For example, Agency A’s records officer, after consulting with agency stakeholders, determines that 5 years satisfies the agency’s business needs. The records officer then applies that disposition to all of the agency’s administrative grievance, adverse action, and performance-based action records, and updates the agency manual and any other relevant agency records management policies. Please note that these items are flexible only within the 4-7-year retention period; they do not allow for longer (or shorter) retention periods based on business need.
2. GRS 2.3, item 060, covers records of grievances filed by non-union employees. Does the GRS address similar records for employees covered by a bargaining unit?
Yes. The items in this GRS do not mean to state or imply policy on who can and who cannot use various methods to formally complain of mistreatment arising from or within the workplace. This item cites “for instance, employees who are not members of a bargaining unit” (emphasis added) only as an example. Records of administrative grievance actions filed by any eligible employee are covered by this item, not just those filed by non-bargaining unit employees. Employees should check with their human resources department to learn which avenues described under GRS 2.3, items 060 through 111 are available to an employee in a given situation.
3. Why does GRS 2.3, item 060 cover such a wide variety of records?
At first glance, administrative grievances (initiated by a staff member) and disciplinary, performance-based, and adverse actions (initiated by the agency against employees) may seem at odds with each other due to who initiates the action and its nature. However, many grievances are filed about subjects or situations in the workplace that also give rise to adverse management actions. Disciplinary, performance-based, and other adverse actions are all variants of such actions. One of the goals of the GRS is to have as few separate items as reasonably possible. We therefore merged these records into a single GRS item because their subject matter is similar, and because OPM provides the same guidance for retention of records created by all of these processes.