Compliance in Türkiye

The staff personnel file: what a hotel keeps for each employee

This guide explains the legal contents of a hotel personnel file in Türkiye. It covers pre-employment documents, health data separation, and the ten-year retention rule for social security records.

  • 11 min read
  • AI Otel Editorial

AI draft · awaiting editorial review

Contents

Key takeaways

  1. Turkish labour law requires a personnel file for every worker, holding identity details and the documents the employer must prepare under that law and other laws, and the employer must show it to authorised officials on request.
  2. The labour law sets no retention period of its own; social security regulations require workplace books, records and documents to be kept for a set number of years and produced when inspectors ask. Confirm the exact period and the date it starts from with your accountant or legal adviser.
  3. Staff identity notifications are a separate duty from guest notifications. Confirm the specific form, the timing and the delivery method with your legal adviser.
  4. A health report belongs in a separate, restricted file; the general personnel file records only that the requirement was met and on what date.
  5. A file is only as useful as its index: one page listing each document, the date it was added, who added it, and whether a text requires it or it is good practice.

A personnel file (özlük dosyası) is the record an employer must keep for every worker under Article 75 of the Labour Law: identity details plus every document the employer must prepare under that law and others, shown to authorised officials on request. Article 75 sets no retention period; Article 86 of Law 5510 requires ten years for social security records.

A seasonal hire starts on Saturday. By Monday the hotel has a signed contract, a social security entry and a Form 2 delivered to the local law enforcement unit, and that thin folder is already the first thing an inspector, an SGK query or a labour dispute will ask for. This article walks through what a personnel file in Türkiye contains at each stage of employment: before the first shift, during the job, and after the person leaves. By the end you will be able to build an index for your own files, mark each line as required or good practice, and know where health data and retention periods fit.

What does the law actually require a hotel to keep?

Article 75 of the Labour Law requires a personnel file for every worker. It holds the worker's identity details and every document and record the employer must prepare under that law and other laws, and the employer must show it to authorised officials and bodies on request, as the consolidated text on the Mevzuat Bilgi Sistemi (opens in a new tab) shows (4 November 2026).

Two duties sit behind the folder, and two kinds of inspector read it. Labour inspectors work under Article 75 of Law 4857. SGK officials work under Article 86 of Law 5510, which covers workplace books, records and documents, and gives the employer fifteen days to produce them.

Article 75 defines the file by reference, not by list. It does not name a single document; it points to every other text that obliges the employer to prepare one. The contents of a correct file therefore change as the law changes, which is why a template found online ages badly.

Article 75 also carries a confidentiality duty of its own. The employer must use information about the worker in line with honesty rules and the law, and must not disclose information the worker has a legitimate interest in keeping confidential. That sentence is the bridge to KVKK, the personal data protection law, discussed below.

Treat the file as evidence, not storage. If a document cannot be produced inside fifteen days, for practical purposes it does not exist. Split every line in your index into two kinds: documents an official text asks for, and good practice. Mark which is which, so a new HR person does not treat a template item as a legal duty, or the reverse.

The duty attaches to the worker, not the contract type. Seasonal, part-time and temporary staff each need a file of their own.

Key pointArticle 75 does not list documents

It points to every other text that obliges the employer to prepare one. Build the index from the texts, not from a template found online, and mark each line required or good practice.

What goes into the file before the first shift?

Identity details, the contract, the social security entry and the staff identity notification, in that order. The notification has its own delivery window; confirm with your adviser what starts the count, because the order above assumes the clock begins with the start of work.

Identity details come first. Whether that means a photocopy of the identity card or a recorded set of fields is a question for your adviser; hold the minimum the law requires and write down why you hold it. Next, the contract, or a signed written summary of its main terms. Later changes go in as dated annexes; never rewrite the original.

In practice the social security entry notification is made before the person starts work; the exact timing and any corrections belong to your payroll adviser, not to a folder. Then comes Form 2, the staff identity notification, which is a separate duty from the guest KBS notification; a hotel that files one and not the other is half covered. The details are worth a separate read in KBS staff notification: identity reporting for the people who work at a hotel.

Under Article 8 of the Identity Notification Regulation, the responsible operator writes the identity of everyone employed at the lodging facility, permanently or temporarily, on two copies of the Employee Identity Notification Form, and delivers them to the nearest competent general law enforcement unit within 24 hours. Other commercial workplaces have three days. Since the amending regulation of 17 June 2022 (opens in a new tab), the same notification may also be made electronically, within the same time limit, by connecting to the law enforcement's computer terminals.

ChecklistBefore the first shift

  • Identity details recorded
  • Contract, or signed summary of terms
  • Social security entry notification
  • Form 2, two copies, delivered within 24 hours or filed electronically
  • Signed job description (good practice)
  • Emergency contact (good practice)
  • Uniform and equipment receipt (good practice)

Which documents are specific to hotel work?

Three groups sit on top of the standard file: food hygiene training and health reports for staff who handle food, occupational safety training records for everyone, and work permits for foreign staff.

Hygiene training and the health report attach to the role, not the person. When someone moves from housekeeping to the breakfast room, the new document goes in before the first shift in the new role. Confirm the scope with your adviser rather than assuming every employee is covered; the question of who the regulation covers is examined in hygiene training certificates for hotel staff.

The health report itself goes into a separate health file. The general file records only that the requirement was met, and the date. Occupational safety training records need the date, the content and the worker's signature; the required content and hours follow the workplace's hazard class, so confirm them with your safety expert or adviser and make the record show which training was given when.

Foreign staff must hold a valid work permit. Keep the permit and record its expiry date in the index so renewal is a diary item, not a surprise; confirm the timing with your adviser.

DocumentStatusWhy it existsOwner
Hygiene training certificateRequired by role; confirm scope with adviserFood safety dutyKitchen chef
Health report for the jobRequired; separate health fileFitness for the roleHR
Safety training recordRequired; hours by hazard classOccupational safety lawSafety expert
Work permit (foreign staff)Required; check expiryEmployment of foreign nationalsHR
Form 2Required; 24-hour clockIdentity notification to law enforcementHR
Uniform and lojman receiptGood practiceExit deductionsDepartment head

Uniform, lojman and equipment receipts are good practice, and they are the cheapest defence in a deduction dispute at exit. Give every line an owner and a review date. A document with no owner is a document that expires quietly.

What gets added while the person works?

Everything that changes the terms or proves a duty was met: leave records, overtime consent and hours, warnings with the worker's response, payroll evidence and training certificates.

Annual leave records need the dates taken, the balance and the worker's signature. The balance is what a dispute turns on, and it is the line most often missing. For overtime, keep the worker's written consent for the period and the record of hours worked; consent given once at hiring and never refreshed is a common weak point, so confirm the form and the period with your adviser.

Warnings and disciplinary notes should carry the worker's written response next to the warning, and a note of who was present when it was given. Payroll means payslips and proof of payment, either in the file or referenced from a payroll index that points to where they are held. Changes of role, department or pay go in as dated annexes signed by both sides. Training certificates carry their date and the name of the trainer or institution, so the hotel can show what was taught and when.

TipKeep a one-page index at the front of every file

Each line carries the document, the date it was added, who added it, and whether a text requires it or it is good practice. An inspector who can read the index in a minute asks fewer questions.

What closes the file when someone leaves?

An exit record: the last working day, the social security exit code, the final pay calculation, and the signed return of everything the hotel issued.

The exit notification to SGK carries a code, and the code decides what happens next for the person and for the hotel. Season-end codes are their own subject, covered in SGK exit codes at season end. Final pay includes the leave balance, notice, and any deduction with its written basis attached; a deduction with no paper behind it is the beginning of a claim.

Returned items, uniform, key card, equipment, lojman keys, are each signed for on the last day rather than promised for later. Close with a signed statement of the final settlement, a copy given to the worker and a copy kept.

Then do not close the file. The exit is a page in it, not the end of it, and the retention clock keeps running after the person has gone. Note the exit date and the storage location in the index, so a query two years later does not depend on someone's memory.

Who may see a personnel file, and where do health records go?

Only the people whose job needs it, and health information goes into a separate file with a shorter access list.

Article 75 already carries the principle: use information about the worker honestly and lawfully, and do not disclose what the worker has a legitimate interest in keeping confidential. Under KVKK, the worker is a data subject. The hotel must be able to say what it holds, why it holds it, how long it keeps it, and who inside has seen it.

Health data is the most sensitive line in any file. Keep the document in a separate folder, restrict it to the person who needs it, and record who opened it. Practical controls: a locked cabinet or a permissioned folder, one named owner, no personal copies on laptops, no photographs sent through messaging apps.

Destruction happens on a schedule, with a log of what was destroyed and when. Keeping personal data beyond its purpose is itself a problem, not a safe default. Tell new staff at hiring what the file holds and who sees it; that five-minute conversation is cheaper than a complaint.

Watch outHealth reports do not belong in the general file

Never keep a health report, a disability note or a pregnancy notification in the general personnel file. Keep the fact that the requirement was met, and the date, in the general file; keep the document itself in a separate, restricted health file.

How long does a hotel keep a personnel file?

Article 75 sets no period. Article 86 of Law 5510 requires workplace books, records and documents to be kept for ten years, counted from the start of the year after the year they relate to, as the Mevzuat Bilgi Sistemi consolidated texts (opens in a new tab) show (4 November 2026).

The clock runs per record, not per person. A 2024 warning and a 2026 contract can reach the end of their periods in different years. For example, a contract signed in March 2026 is kept until the end of 2036 under that rule, because the count starts on 1 January 2027.

The fifteen-day window matters as much as the period. SGK officials charged with inspection and control can ask for the records, and the employer must produce them within that window, so storage must be findable, not merely legal. Article 75 has no period of its own, so do not invent one. Where another text sets a longer period for a specific document, follow that text and confirm it with your adviser.

Build a retention table: document, legal basis, period, destruction date. It turns a vague worry into a list someone can work through once a year. Destruction is part of the duty, not the opposite of it; a file kept forever is a KVKK exposure, not diligence. The same method applied to guest records is described in how long a hotel should keep guest records.

NoteWhen the ten-year count starts

The count under Article 86 of Law 5510 starts on 1 January of the year after the year the record relates to. A record from 2026 is therefore kept to the end of 2036, not the end of 2035.

What to do next

Start with the index, not the folder. Take one current personnel file, list what is inside against the texts, and mark each line required or good practice. Then close the gaps before the next hire, and confirm the timing, retention and health-data questions with your accountant or legal adviser, because the general duty is clear while the detail depends on your own case.

Frequently asked questions

Is a personnel file required for seasonal and part-time staff?

Yes. Article 75 of the Labour Law attaches the duty to every worker, not to the contract type, so a three-month seasonal hire needs a file of their own. The folder is the same; what differs is the contents, since some hotel-specific documents depend on the role rather than the length of the contract.

Does the guest KBS notification also cover hotel staff?

No. Staff notification is a separate duty under the Identity Notification Regulation, made on Form 2, two copies, delivered to the nearest competent general law enforcement unit within 24 hours for a lodging facility, or filed electronically within the same limit since the 17 June 2022 amendment. Guest notification is a different form and a different process.

Can a personnel file be kept electronically?

Article 75 requires the file to be shown to authorised officials and bodies on request, and Article 86 of Law 5510 requires production within fifteen days. Whether a scanned file satisfies that in your case is a question for your adviser. Keep signed originals where a signature matters, and make sure any electronic copy can be produced inside the window.

How long after an employee leaves must the file be kept?

Article 75 sets no period. Article 86 of Law 5510 requires ten years from the start of the year after the year the record relates to, and the exit does not reset that clock. Where another text sets a longer period for a specific document, follow that text and confirm it with your accountant or legal adviser.

Where should a health report for the job be kept?

In a separate, restricted health file, not in the general personnel file. The general file records only that the requirement was met and the date. Access to the health file should be limited to the person who needs it, and access should be recorded.

Sources

AI Otel EditorialEditorial team

Drafted with AI assistance from AI Otel’s published fact base. Not yet reviewed by an editor.

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