Paper personnel files are rarely HR’s only problem. Some documents are in folders, others are in the payroll and HR system, and scans circulate through email and network drives. An HR specialist knows the archive structure, but the system cannot identify a missing signature, an expiring medical certificate, or a document filed in the wrong part of the personnel records.
Moving to eTeczka (electronic personnel files) is therefore not a mass-scanning project. It changes how employee documentation is maintained: the organization must determine the source, category, metadata, retention period, permissions, and subsequent path of every document. Only then should archive digitization begin.
The plan below reflects the law in effect on October 10, 2026. Before launch, an organization operating in Poland should have its legal department, data protection officer, and HR owners approve the plan.
eTeczka is employee documentation, not a folder of scans
The Polish Labor Code allows employee documentation to be maintained and stored in paper or electronic form. In both cases, the employer is responsible for its confidentiality, integrity, completeness, and availability for the required period. An eTeczka system must therefore do more than make PDF files available.
Electronic records should identify people with access, record changes, search documents by metadata, print them, and issue or export documentation in the required structure. The organization also needs procedures for access, backups, responding to threats, and maintaining long-term file readability.
Two terms should be separated from the outset:
- personnel files consist of five parts, A–E;
- other documentation related to employment includes working-time records, leave documents, the pay record, and documentation concerning the allocation of workwear and personal protective equipment.
Not every HR document should therefore automatically enter one of the personnel-file sections.
What belongs in parts A–E of personnel files
Polish employee-documentation regulations define five parts of the personnel file. During migration, map them in the document catalog, completeness rules, and permissions:
- part A — documents related to applying for employment, including candidate data and specified medical examination referrals and certificates;
- part B — documents concerning the establishment and course of employment, such as the employment contract, information about employment terms, occupational health and safety training, changes to employment terms, and remote-work documents;
- part C — documents related to termination or expiration of employment, including declarations by the parties and a copy of the employment certificate;
- part D — documents concerning disciplinary or other liability for which the law provides for the penalty to be expunged;
- part E — documents related to sobriety testing and testing for substances that act similarly to alcohol.
Documents are stored chronologically and numbered, and each part contains an index. Related documents in parts A, B, and C can be kept in separate subsections such as A1, B1, or C1. For parts D and E, the regulations provide for separate sets concerning a particular penalty or test. This matters because the entire applicable subset must be removed after the relevant period, rather than an arbitrary file found by name.
Determine the retention period before migration
Using one retention date for all files is a mistake. The period depends in part on when employment began:
- for employment relationships beginning on or after January 1, 2019, documentation is generally retained for 10 years from the end of the calendar year in which the employment relationship ended;
- for employment relationships beginning from January 1, 1999, through December 31, 2018, the period is generally 50 years, but it can be reduced to 10 years after the conditions connected with ZUS OSW and ZUS RIA reports submitted to ZUS (Poland’s Social Insurance Institution) have been met; the retention period is then calculated differently;
- for employment beginning before January 1, 1999, the 50-year period under the earlier regulations remains in effect.
Documentation must be retained longer if separate provisions require it or if it may constitute evidence in proceedings. Retention should therefore follow rules assigned to the specific employment relationship and document type, not a manually entered deletion date for the entire file.
What migration looks like in practice
1. Inventory: what is actually in the archive
The team selects a representative sample of files: current and former employees, different employment years, companies, branches, and contract types. For each group, it compares the list of required documents with the contents of paper files, drives, email, and HR systems.
The outcome is more than a binder count. It is a map of categories, formats, gaps, duplicates, paper quality, sensitive data, exceptions, and decision owners.
2. Target model: file parts, metadata, and accountability
Before scanning, agree on the document catalog, assignment to parts A–E or documentation outside the personnel file, required metadata, numbering, and versioning rules. Every document type receives an owner, retention period, and access scope.
This is also the point at which the organization decides which system is the source of employee data and which one manages the document and process status. Without this decision, migration creates another copy that no one can identify as current.
3. Digitization pilot before mass production
A small, varied batch reveals problems that are not visible in a spreadsheet: double-sided documents, staples, unusual formats, faint copies, several documents on one page, or the lack of an unambiguous employee identifier.
Quality control should cover readability, complete page sets, correct orientation, assignment to the right person and category, metadata consistency, and duplicate detection. An error found after scanning the entire archive is far more expensive than correcting the rule after the pilot.
4. Changing the form of the documentation
Changing from paper to electronic form requires a digital reproduction, such as a scan, bearing the employer’s qualified electronic signature or qualified electronic seal. A person authorized by the employer can also apply the qualified signature. It confirms that the reproduction is consistent with the paper document.
Employees must be informed about the change in form and their option to collect the previous form within 30 days. Former employees are notified individually. The employer can then destroy an uncollected previous form in a manner that prevents its content from being reconstructed.
5. Data migration and acceptance
Documents enter eTeczka in batches. Each batch should have a record identifying its scope, number of documents, errors, quality-control result, and approver. Acceptance testing does not end when a file opens. It covers search, permissions, change history, export, backup restoration, and issuing a copy to the employee.
When documentation is moved between systems, each document is a separate file, and reproductions of paper documents are transferred as PDFs. Specified metadata accompanies the documents in XML files. Export requirements should be tested before a solution is selected to prevent the archive from becoming dependent on one provider.
Is the archive larger than the team can organize safely by hand? We will begin with a sample of files, classification rules, and a quality-control plan. Discuss migration to eTeczka →
Key decisions before selecting a system
Permissions and GDPR
Access should not follow solely from membership in HR. It must account for the company, branch, role, document type, process stage, and substitute. A system administrator should not always see document content, and a manager should not see the employee’s entire file.
GDPR principles translate into specific functions and procedures: limiting the purpose and scope of data, retention, confidentiality, integrity, availability, a change log, incident handling, and regular security assessments. Access and deletion decisions must leave a trace.
Signing a document and certifying a scan
These are two different events. A signature under a contract or declaration confirms a person’s intent or knowledge. A signature or seal used in digitization confirms that the scan is consistent with the paper original. The system should retain the document, signatures, and data needed for later verification.
If a document must preserve written form, its electronic form requires a qualified electronic signature. This includes an employment contract. Do not assume that every click, SMS code, or Polish trusted signature replaces a qualified signature for every document. The legal department should specify the required form for each document type.
Integration with the payroll and HR system
The integration should exchange data in both directions: the employee identifier and record, organizational structure, employment dates, document status, signature information, and exchange errors. The system of record for each field and the discrepancy-handling procedure must be defined.
The HR and Electronic Personnel Files solution page explains how the full employment life cycle connects with eTeczka.
Checklist before launching eTeczka
- Have paper files, drives, email, and documents in HR systems been inventoried?
- Is every document type assigned to parts A–E or documentation outside the personnel files?
- Have metadata, numbering, order, and versioning rules been established?
- Does retention account for the employment date, ZUS OSW and ZUS RIA reports, and proceedings that require longer retention?
- Is it clear who certifies the digital reproduction and how a qualified seal or signature is used?
- Have employee notifications and collection of the paper form been planned?
- Does the pilot include difficult documents, former employees, and several companies or branches?
- Does quality control detect missing pages, the wrong person, category, or date, and duplicates?
- Do permissions restrict access by role, unit, and data type?
- Does the integration identify the source of every field, retries, and error handling?
- Have export with metadata, issuing a copy, and document restoration been tested?
- Is there a procedure for deletion after the retention period, placing deletion on hold, and documenting the decision?
Completeness should be controlled while documentation is being created, not only during an audit. Practical examples are described in the article “Completeness checked along the way: eight gates in hiring.”
How automation organizes eTeczka
In AMODIT, we build a process from receiving or creating a document, through data verification and signature, to filing it in the correct part of eTeczka. Rules identify the responsible person and manage completeness, deadlines, and permissions, while the integration exchanges data with any payroll and HR system.
AI and OCR support scan reading and classification. AI prepares the result, and a person reviews and approves the document assignment and data before they are saved. We use existing models and configure them for the client’s process. We process AI data in a controlled environment in EU regions; the models are not trained on client data, which ensures compliance with the GDPR and the EU AI Act.
When a standard process is not enough, Astrafox builds custom HR applications, employee portals, and integrations. We then connect the solution with electronic signature services and systems from other providers used by the organization.
Our implementations cover more than 100,000 electronic personnel files, including more than 40,000 eTeczka files in one organization. At this scale, migration success depends on repeatable rules, batch control, and exception handling rather than one person’s memory.
The difference between a document repository and a digital HR process is discussed further in the article “HR digitization is more than eTeczka.”
FAQ: moving from paper to eTeczka
Is scanning paper files to PDF enough?
No. A scan must be readable, assigned correctly, and connected to metadata, while changing the form of the documentation requires certification with a qualified signature or seal. The system must also protect integrity, record access, and support the required export.
Are all personnel files retained for 10 years?
No. The 10-year period generally applies to employment relationships that began in 2019 or later. For employment from 1999 through 2018, reducing the period from 50 to 10 years depends on the ZUS OSW and ZUS RIA procedure. Earlier employment remains subject to the 50-year period. Legal exceptions and proceedings can extend retention.
What happens to the paper after the form of the documentation changes?
The employer informs employees that they can collect the previous form within 30 days and notifies former employees. If the documentation is not collected, the employer can destroy it in a way that prevents the content from being reconstructed.
Does every employee document require a qualified electronic signature?
No. The required form depends on the document type and act. A qualified signature or seal is used to certify the digital reproduction when changing from paper to electronic form. For an employment contract, each party signing the electronic document uses a qualified electronic signature so that the declaration is equivalent to one made in written form.
Does the payroll and HR system need to be replaced?
No. eTeczka and the process can be connected to the existing payroll and HR system. The requirements are clear responsibility for data, an available integration method, and status and error handling.