In short:
- HR software must only contain the personal data needed for personnel management.
- Access is reserved for the people in charge of personnel management, with managers only accessing the data useful for their duties.
- Employees must be informed of the processing and can access their file without justification.
- The personnel management file must appear in the record of processing activities.
HR software: regulated data processing
Any HR software, whether a full HRIS, payroll software or a leave management tool, processes personal data. On 17 August 2023, the CNIL (the French data protection authority) published a reference page on the rules that apply to personnel management.
Data that can be collected
The employer can collect the information needed for:
- the administrative management of staff;
- the organisation of work;
- social benefits for employees.
The CNIL gives the examples of the type of driving licence held or the contact details of a person to notify in an emergency.
Who can access the data?
| Profile | Access |
|---|---|
| People in charge of personnel management | Viewing the information in the file |
| Line managers | Only the data needed to carry out their duties |
| Third parties | No disclosure of personal contact details, unless required by law or a court decision |
Retention period
Data is kept while the employee is with the organisation. After departure, some of it must be archived. This is the case for the French payslip, a copy of which the employer keeps for 5 years.
Information and employee rights
The employer informs employees about:
- the identity of the data controller;
- the purposes pursued and the legal basis;
- whether answers are mandatory or optional;
- the recipients of the data;
- the retention period;
- how to exercise their rights.
Employees can request access to their file without justifying the request: recruitment records, career history, pay, appraisals.
Points to check before choosing a tool
- Enter the processing in the record of processing activities and involve the data protection officer if there is one.
- Set access rights by profile.
- Check that the fields provided match the information an employer can ask a job candidate.
- Identify the features that rely on artificial intelligence, governed by the rules on AI in recruitment.
- Check the tool’s ability to produce the DSN (nominative social declaration) if it handles payroll.
Security and access traceability
The CNIL expects the employer to keep information secure and to ensure that only authorised people can view it.
Actions carried out on the data by authorised people must be logged. The aim is to know who connects to what, when and to do what. HR software must therefore make it possible to trace connections and operations.
Staff representatives
Staff representatives have access to the data in the single staff register: name, nationality, job held, date of joining the organisation. Other bodies can obtain certain information needed to carry out their duties.
Frequently asked questions
What personal data can HR software contain?
According to the CNIL, the employer can collect the information needed for the administrative management of staff, the organisation of work and social benefits. Only the people in charge of personnel management can view this data, and line managers only access the information needed for their duties.
How long should employee data be kept?
Data is kept for as long as the employee is with the organisation. After departure, some information must be archived, such as payslips, which are kept for 5 years.
Can employees access their file in the HR software?
Yes. Employees can request access to the data concerning them without having to justify the request, including items relating to their recruitment, career history, pay and appraisal.
Sources
- CNIL, Les règles pour la gestion du personnel, page dated 17 August 2023, consulted on 4 October 2026.