Personnel file requirements in Türkiye: what the file must hold and how long to keep it

What is a personnel file under Turkish law?

A personnel file is the file an employer keeps for each employee, holding the employee’s identity details together with every document and record the employer is required to produce under the law. Its basis is article 75 of Labour Law No. 4857: the employer must keep these documents and show them to competent officials and authorities on request.

The law does not prescribe a format: a paper folder, scanned documents or an electronic record all qualify. What it does require is that the file is complete and can be produced during an inspection. A missing document is usually discovered not in an inspection but in a dispute, and by then it cannot be recreated after the fact.

The duty does not depend on headcount: an employer with a single employee keeps a file too. Who maintains it — HR, accounting or an outside payroll accountant — does not move the responsibility, which stays with the employer, and the documents must be producible from the workplace.

The employer’s confidentiality duty

The employer must use information obtained about the employee in good faith and lawfully, and must not disclose information the employee has a legitimate interest in keeping confidential (art. 75/2). The provision predates the Personal Data Protection Law No. 6698 by many years and today is read together with it.

Under KVKK the employer is the data controller for the personnel file. It must take the technical and administrative measures needed to prevent unlawful processing and unlawful access and to safeguard the data (6698 art. 12/1). In practice: defined access, a locked cabinet or authorised user accounts, and access that can be traced.

Documents the personnel file must hold

The contents depend on the employee’s situation; the table lists the documents whose legal basis we confirmed in the primary texts. Not every file holds all of them: a part-time contract is needed only for a part-time employee, an equipment list only for a remote worker.

The list covers documents whose basis this guide verified in the primary text; depending on the activity, other rules such as occupational health and safety legislation may require further records.

For the remote-work document see the remote work regulation guide; for how overtime consent is obtained see the overtime guide.

How long must a personnel file be kept?

The Labour Law sets no single retention period for the personnel file; the period follows the law each document rests on. The longest is usually SGK’s: workplace books, records and documents are kept for ten years starting from the beginning of the year following the year they relate to (5510 art. 86/2).

A limitation period is not a retention duty; but proving a claim depends on documents, so destroying them before the limitation period runs out leaves the employer without evidence.

Example. For an employee who left in March 2026, the 2026 SGK records are kept for ten years from 1 January 2027 — until the end of 31 December 2036. The tax period for that year’s payroll runs five years from the start of 2027 and ends in 2031; but payroll is also an SGK record, so in practice keeping it for the longer period is the safe course.

Rather than closing the file when the employee leaves, set a destruction date per document: a timesheet kept until 2036 and an application form whose period ran out long ago can sit in the same file.

What should not go into the file?

Personal data must be relevant, limited and proportionate to the purpose for which it is processed (6698 art. 4/2-ç). The personnel file is not a folder for “everything about the employee”; every document in it needs a legal requirement or a clear purpose.

• Keep health data separate. Health data is a special category of personal data (6698 art. 6/1). Medical reports may be needed, but access should be narrow and they should sit apart from the general file.
• Do not ask for unnecessary copies. If only part of a document is needed, do not collect the rest.
• Social media screening, family details, political views and other information unrelated to the job should stay out; association or trade-union membership and religion are special-category data too.
• Notes and assessments should be dated and signed; an unsigned note of unknown authorship is the weakest document in any file.

When data is collected, the employee must be told the purpose, to whom it may be transferred, the method of collection and the legal ground (6698 art. 10). The privacy notice given on hiring should cover the personnel file itself.

Hiring, employment, leaving: a three-stage checklist

A personnel file is not built once and closed; it grows throughout the employment. Checking documents at the stage they are created catches a gap in the month it occurs.

On hiring

• Identity details and a copy of the SGK start notice, filed before work starts (5510 art. 8/1).
• Signed employment contract; without one, a written statement of conditions, working hours, pay and pay period within two months (Labour Law art. 8).
• Written overtime consent if overtime is foreseen (Overtime Regulation art. 9).
• A record that the privacy notice was given (6698 art. 10).
• For remote work, the signed equipment list (Remote Work Regulation art. 7/2).

During employment

• Monthly pay statement and payroll; in months with missing days, the document proving the reason (report, leave form, signed timesheet or incident report).
• Signed copies of the documents showing overtime hours (Overtime Regulation art. 10).
• Entitlement and usage dates in the annual leave record (Paid Annual Leave Regulation art. 20).
• Written warnings, requests for a defence and reports; where a notice is not signed, a report drawn up on the spot (Labour Law art. 109).

On leaving

• Written termination notice or resignation letter; notices leading to termination are always in writing (art. 109).
• Employment certificate showing the type and length of the work (art. 28).
• A record of returned equipment.
• Destruction dates noted per document — the file closes with its last record’s period, not with the departure.

The three most common gaps: unsigned overtime records, months with missing days left undocumented, and no written statement of conditions given within two months to an employee without a written contract. All three surface only when a dispute begins, and none can be fixed retroactively.

How are expired records destroyed?

Once the reasons for processing cease, personal data is erased, destroyed or anonymised on the controller’s own initiative or at the data subject’s request (6698 art. 7/1). The procedure is set by the Regulation on the Erasure, Destruction or Anonymisation of Personal Data.

• An employer required to register with the Data Controllers’ Registry prepares a personal data retention and destruction policy (Regulation art. 5/1).
• With a policy, expired data is erased at the first periodic destruction; the interval is set in the policy and may not exceed six months. Employers without a policy duty act within three months (art. 11).
• Erasure, destruction and anonymisation are logged and the log is kept for at least three years (art. 7/3).
• If an employee asks for erasure and all processing conditions have ceased, the request is concluded within thirty days (art. 12).

The usual mistake is getting the order wrong: KVKK says “erase what is no longer needed”, while social security and tax law say “keep this for so long”. KVKK preserves the provisions of other laws (6698 art. 7/2). A timesheet whose retention period is still running is not erased even if the employee asks; once the period ends it is destroyed without delay.

Electronic personnel files and inspections

An electronic file can be safer than paper, but only if two conditions hold: access is limited by authorisation and changes leave a trail. A system where a timesheet can be edited afterwards without showing who edited it is weaker evidence than a paper sign-in sheet.

Inspection deadlines are short: when an SGK inspector asks, documents are produced within fifteen days (5510 art. 86/2; for missing-work documents, SSİY art. 102/13). An arrangement searchable per employee, not per team, makes that deadline realistic.

Our software is not a personnel-file archive; it produces some of the records the file needs. Timesheets are built automatically from clock-ins, days on leave, on medical report and with missing work are counted separately, an approved month is locked and exported as PDF, CSV or Excel. Overtime cannot be approved for an employee without recorded overtime consent; documents such as medical reports are stored encrypted and every view is logged; time-limited documents such as OHS training and medical checks trigger a notification before they expire. Details: timesheets.

This guide is for information only and is not legal or payroll advice. Your collective agreement or employment contract may contain more favourable terms.