Managing Access to People Data During Performance Reviews: A Strategic Approach
Introduction
Performance reviews are one of the most data-sensitive processes in People Operations. Whether it is a mid-year check-in or an end-of-year evaluation, HR teams manage confidential data, including feedback, ratings, compensation adjustments, and promotion decisions.
The challenge is ensuring that the right people have access to the right data at the right time—without compromising security or creating bottlenecks. Performance reviews require coordination across HR, managers, and leadership, and without proper access controls, data can be either too restricted (slowing down decision-making) or too open (leading to confidentiality risks).
Key Considerations for Managing People Data Access in Performance Reviews
Performance evaluations involve multiple stakeholders, each needing different levels of access. If access is too broad, sensitive feedback and compensation discussions may be exposed to the wrong people. If it is too restricted, managers may not have the information they need to make fair decisions.
To prevent these issues, HR teams should focus on three key areas:
- Defining Clear Access Levels – Who needs to see what?
- Implementing Secure Data Management Systems – Where is the data stored and shared?
- Ensuring Compliance and Confidentiality – How do we prevent leaks or unauthorized access?
1. Define Clear Access Levels: Who Needs to See What?
Not everyone in the People team or leadership needs full access to all performance review data. Access should be role-based and need-to-know to maintain security while enabling efficiency.
Access Tiers for Performance Review Data
| Role | Access Level | Purpose |
|---|---|---|
| HR Leadership | Full Access | Oversee all performance review processes, approve final ratings, promotions, and compensation adjustments. |
| HR Business Partners (HRBPs) | Limited Access (Own Departments) | Support managers in performance reviews, ensure fairness in evaluations, and advise on compensation discussions. |
| Managers | Limited Access (Own Team) | View and submit performance reviews for direct reports but cannot see compensation changes before final approvals. |
| Compensation & Benefits | Full Access (Comp & Benefits Data Only) | Process salary adjustments, bonuses, and promotion-related pay changes. |
| Finance Team | View-Only (Aggregated Data) | Align budget planning with approved compensation and promotion decisions. |
| IT & Systems Administrators | Temporary Access (Technical Support) | Ensure systems function properly for data reporting and approvals. |
Key Actions:
- Restrict access based on job function – No unnecessary visibility into employee ratings or compensation discussions.
- Apply “need-to-know” access – HRBPs should only see data for employees in their assigned business units.
- Time-limit certain accesses – Grant temporary access for performance review periods, then revoke it once the process is complete.
2. Implement Secure Data Management Systems
Performance review data is often handled across multiple platforms—HRIS systems, performance management tools, spreadsheets, and compensation planning systems. Without structured access management, sensitive information can be exposed or lost.
Best Practices for Data Storage and Access:
- Use centralized, secure HR platforms – Ensure all sensitive data is stored in a system with role-based access controls rather than shared files.
- Limit spreadsheet use – If spreadsheets must be used, restrict access with password protection and version control.
- Control data exports and sharing – Prevent unnecessary downloads or external sharing of confidential information.
Key Actions:
- Store all final performance, promotion, and compensation data within the HR system, not in email attachments or personal drives.
- Restrict “export” capabilities to prevent data leaks.
- Log all data access activities to track who is viewing or modifying information.
3. Ensure Compliance and Confidentiality
Performance reviews contain highly sensitive feedback and compensation data that must be protected to maintain trust and comply with privacy regulations.
Steps to Ensure Data Security and Confidentiality:
- Limit Internal Visibility – Employees should not have early visibility into salary changes or promotion decisions before final approvals.
- Use Multi-Factor Authentication (MFA) – Ensure that anyone accessing critical data must authenticate their identity.
- Audit and Review Data Access Logs – Track who accessed or modified data to detect any unauthorized access.
Communication Strategy for People Data Access:
- Train HR teams on confidentiality protocols—remind them not to discuss sensitive compensation or promotion decisions before they are finalized.
- Establish a clear workflow for approvals—ensure leadership and finance sign off before any announcements are made.
Key Actions:
- Set strict deadlines for access removal after the performance review cycle is complete.
- Encrypt sensitive data when transferring between systems.
- Use automated alerts for unusual access patterns.
Final Thoughts: Balancing Efficiency and Security in Performance Reviews
Managing people data access during performance reviews requires a careful balance between security and usability. People teams need enough access to do their jobs efficiently without exposing sensitive information to unnecessary risks.
By defining clear access roles, securing data storage, and enforcing confidentiality measures, HR can ensure that performance reviews run smoothly while protecting employee data.
How does your organization handle access to people data during performance reviews? Let’s continue the conversation.