Digital Personnel Files in Turkey: What They Must Contain, Who May See Them and How to Go Paperless

A personnel file is the record a Turkish employer must keep for every employee, holding identity details, the employment contract, social security filings, training certificates and health documents. Going digital makes documents quicker to find, but the real gain is control over who sees each one, how long it is kept and what is missing.

Key takeaways

• Article 75 of Labour Law No. 4857 requires employers to keep a personnel file for every employee, to use what they learn about workers lawfully and not to disclose information the worker has a legitimate interest in keeping confidential.
• Personnel files hold special category personal data under KVKK, such as health reports and criminal records, so access should be limited to people whose job requires it.
• Türkiye's Personal Data Protection Authority (KVKK) received 244 notices and complaints related to the human resources sector in 2025.
• A good digital personnel archive combines per-employee folders, role-based access, missing-document tracking, retention periods and an activity log.
• Before going digital, agree with your legal adviser which wet-signed originals to keep and when the rest may be destroyed.

What is a personnel file and why is it mandatory?

Article 75 of Labour Law No. 4857 obliges employers to open a personnel file for each worker at the workplace. The file holds identity details and every record the law requires, and must be shown to the authorities on request. The same article requires employers to use what they learn about workers in good faith and lawfully, and not to disclose information the worker has a legitimate interest in keeping confidential.

So a personnel file is not just a folder of paperwork; it is also a confidentiality duty. We cover the lawful grounds for processing this data in employee personal data under KVKK. In short, most documents rest on performance of the employment contract or the employer's legal obligations, so consent is rarely needed.

What documents belong in a personnel file?

Contents vary with the job, the sector and the workplace hazard class. The table lists typical documents and their sensitivity; treat it as a starting checklist, not legal advice.

Training certificates deserve a special mention. Article 15 of the regulation on employee health and safety training explicitly requires them to be kept in employees' personnel files. To track refresher dates without spreadsheets, see our guide to digital tracking of OHS training records.

What does a scattered personnel file cost?

A file in a cabinet or shared folder has two risks: the wrong person sees it, or the right one cannot find it. According to KVKK's 2025 Annual Report, the authority received 244 notices and complaints from the human resources sector that year. It also lists 689 complaints about unfulfilled data subject requests and 551 about failure to erase data.

Both categories cover every sector, but both are common problems in personnel archives. When a former employee asks what you hold about them, Article 13 of Law No. 6698 gives you 30 days at most to answer. For an HR team searching three cabinets and five mailboxes, that is not long. We set out the process in handling KVKK data subject requests.

The other cost shows up in employment disputes. If a signed warning letter or leave record cannot be produced, the employer's case is weaker. A document nobody can locate is, in practice, a document you do not have.

Paper, shared drive or digital archive: which works best?

The differences show when you put the same questions to each model.

The row that matters most is "who opened it". Why shared folder permissions creep wider over time is covered in file sharing permissions, and where to draw the line is explained in our guide to the principle of least privilege.

How do you move personnel files into a digital archive?

Success depends on decisions made before anyone touches a scanner. This sequence suits a mid-sized company over a few weeks.

1. Take stock: Which document types live where: on paper, in email, on a shared drive? Match the list against your personal data inventory.
2. Fix the folder template: One folder per employee, with the same subfolders each time, such as "Joining", "Contract", "Training", "Health", "Leave and discipline" and "Leaving".
3. Write the access matrix: Agree on paper which subfolders the HR specialist, payroll officer, workplace doctor and line managers may see. Keep the health subfolder separate and narrow.
4. Tie retention to policy: The law sets no express period for a leaver's personnel file; keeping it for at least ten years after employment ends is common practice. The details are in our table of company document retention periods in Turkey.
5. Decide what happens to originals: A scanned copy may not carry the full evidential weight of a wet-signed original in every case. Agree with your legal adviser which originals to keep and when the rest may be destroyed.
6. Move current staff first: Leave former employees for a second wave, so the missing-document checklist starts paying off straight away.
7. Define the leaving step: When someone leaves, their file closes, the retention clock starts and access narrows to HR. For the rest of their accounts, see what happens to company files when an employee leaves.

Disposing of files once retention ends is a policy question in its own right. When you draft a retention and disposal policy, list personnel files as a separate category; our data retention and disposal policy guide includes a template.

How should access work in a digital personnel archive?

First, grant access to roles, not individuals: a new HR specialist should gain access on joining the department and lose it automatically on moving elsewhere.

Second, separate permissions. An intern needs to upload but not delete; a line manager may see their team's leave forms but never their medical reports.

Third, leave a trail: every view, download and deletion should be logged and exportable for an audit. Under KVKK, that log is one of the clearest pieces of evidence that you have taken technical measures.

How does SmartFiles support a digital personnel archive?

SmartFiles is the business file management service in Digital Bridge's Smart360 product family. It is not an HR system but the archive layer that stores personnel documents under defined permissions and retention rules. It runs in the cloud, so no server is installed on your premises.

A typical set-up gives HR its own storage area with one folder per employee. SmartFiles has eight independent permissions (read, write, edit, delete, create folders, AI, history and notes), each granted to a person or a department, so an HR intern can upload but not delete. When the health subfolder is restricted to named people, anyone not on the list will not see it in the folder tree, search results or activity history; organisation administrators can always see it.

For missing paperwork, the checklist feature does the chasing: applied to the parent folder, it shows which documents each employee folder has and which are missing. If an administrator has enabled external sharing, a missing document can be requested from a new starter through an upload link, without them needing an account or seeing anything else in the folder. Paper documents can be scanned straight into the right folder with the SmartFiles mobile app.

On compliance, each folder can carry a retention period of 1 to 30 years; expired documents are listed for the person responsible rather than deleted automatically. During a dispute, an administrator can place a legal hold so the file cannot be deleted or moved. Readable documents are scanned for Turkish ID numbers, IBANs and wording that suggests special category data, without using AI. The activity log, with date, person, action and IP address, exports as CSV, and unusually high download or deletion activity triggers an alert.

Use the AI features with care in a personnel archive: while they are on, uploaded documents are analysed automatically and analysis requests pass through Smart360's central AI layer. They can be switched off organisation-wide or granted only to chosen people; decide with your data protection adviser which suits an archive that holds medical reports. How permission limits apply to chatting with documents is explained in AI document analysis.

How can Digital Bridge help with a personnel archive project?

Software alone does not make you compliant; what is held, why, for whom and for how long must be written down first. Through our data protection compliance consultancy, we prepare the data inventory, privacy notices and retention and disposal policy with you.

For organisations that want the personnel archive joined up with payroll, leave and timekeeping, we build and integrate HR, payroll and personnel management software. If you are comparing systems, add the questions in our HR software selection guide to your shortlist.

What should you do next?

Open one employee's personnel file today and answer three questions: is it complete, who can see it, and how long will it be kept if they leave? If you cannot answer all three clearly, it is a good time to move to a digital archive. More articles on the subject are collected on the business email and documents topic page.

When you are ready, explore SmartFiles on the product page and get started from the SmartFiles purchase page; free file migration and expert set-up support are included in the package. If you would like help drawing up the access matrix and retention policy, get in touch through our contact page or call 0850 346 41 09 (+90 850 346 41 09 from abroad).