Personnel file retention periods: what to keep, and for how long?

Pay slips 7 years, performance reviews 2 years, rejection letters 4 weeks. Here's a clear overview of Dutch retention periods — no unnecessary legal jargon.

After an employee leaves, you need to know what you're allowed to keep — and what you're not. Keeping data too long is a GDPR risk. Keeping it too short is a liability risk in employment disputes. Here are the guidelines.

Tax obligations — 7 years

Everything the Tax Authority may request: pay slips, employment contract, terms and conditions, training expense claims, final settlements, annual income statements. The statutory tax retention period is 7 years after the end of employment.

Collective agreements / employment law — varies

• Contract + amendments: 7 years (overlaps with tax obligation).
• Performance and appraisal reports: 2 years.
• Absence and sick leave records: 2 years from end of employment.
• Certificates of Conduct (VOG): as long as required for the role (usually shorter).

Job applicants — short

• Rejected applicants: maximum 4 weeks, unless the candidate has given consent for future recruitment purposes (1 year).
• Hired applicants: data becomes part of the personnel file.

GDPR-sensitive data

• Photos: retain during employment only; delete upon departure unless there is a valid business reason.
• BSN (citizen service number): for payroll administration only.
• Medical data: occupational health physician only — not in the HR file.
• Manager's informal notes: do not retain structurally, and certainly not for 7 years.

Offboarding action point

Set up a retention process: immediately after an employee leaves, categorise the file. Delete any items not subject to a retention obligation. Items falling under the 7-year obligation go to an archive with restricted access.

See also: legal framework for offboarding, processing register.