Major Changes Coming to Illinois Personnel Record Review Act in 2025

Lance C. Ziebell • November 14, 2024


The Illinois Personnel Record Review Act (PRRA) will undergo significant changes effective January 1, 2025, expanding employee rights and imposing new obligations on employers. These amendments reflect a growing focus on workplace transparency and employee access to information.


Expanded Access Rights


Under the amended PRRA, employees gain broader access to their personnel records. Previously, employees could request reviews twice per year. Starting in 2025, employees can make reasonable requests to inspect their records up to four times annually. Employers must provide access within seven working days, reduced from the previous 14-day window.


The definition of "personnel records" has also been expanded to explicitly include electronic communications about an employee's qualifications for employment, promotion, transfer, compensation, discharge, or discipline.


New Employer Obligations


Employers face enhanced record-keeping requirements. They must now maintain personnel records for a minimum of five years following an employee's separation, extended from the previous three-year requirement. This includes preserving electronic communications that may impact employment decisions.


Organizations must also provide written notification to employees whenever disciplinary actions or performance evaluations are added to their personnel file. This notice must be given within 14 days of the addition and include a copy of the new document.


Expanded Disclosure Requirements


The amendments mandate broader disclosure of personnel records during litigation. Employers must now produce all personnel records relevant to employment-related claims or defenses, including internal communications and investigation records previously considered privileged under certain circumstances.


Enhanced Privacy Protections


While expanding access rights, the law strengthens privacy protections. Employers must implement reasonable security measures to protect electronic personnel records from unauthorized access. They must also maintain logs of all internal and external access to employee files.


Penalties and Enforcement


The amendments introduce stronger enforcement mechanisms:

  1. Increased civil penalties for violations, up to $2,500 per occurrence
  2. New provisions for compensatory damages
  3. Attorney fee recovery for successful plaintiffs
  4. Enhanced Illinois Department of Labor investigation powers


Practical Implications for Employers


To comply with these changes, employers should:

  1. Update personnel record policies and procedures
  2. Review and modify electronic communication retention practices
  3. Implement new notification systems for file additions
  4. Enhance security measures for electronic records
  5. Train HR staff on new requirements
  6. Review and update record retention schedules


Small Business Considerations


Organizations with fewer than 50 employees receive some flexibility in implementation timelines and may request hardship exemptions for certain electronic record-keeping requirements. However, core access and retention obligations still apply.


Conclusion


These amendments significantly expand the scope and requirements of the PRRA. Employers should begin preparing now to ensure compliance by January 1, 2025. Organizations should consult with legal counsel to review and update their policies and procedures, particularly regarding electronic communications and record retention practices.


The changes reflect a broader trend toward increased employee access to employment records and greater transparency in employment decisions. Employers who proactively adapt their practices will be better positioned to meet these new obligations while maintaining efficient operations.


If you have any questions regarding these changes, please contact Lance Ziebell at 847-705-7555 or email him at lziebell@lavellelaw.com.

More News & Resources

Lavelle Law News and Events

Consolidated Omnibus Budget Reconciliation Act (COBRA)
By James P. Berg April 27, 2026
Losing a job or experiencing a change in employment status can be stressful, particularly when it impacts health insurance coverage. The Consolidated Omnibus Budget Reconciliation Act (“COBRA”) provides a critical safety net by allowing employees and their families to continue employer-sponsored health coverage.
Success Story - Strategic Defense in Probate Property Dispute
By Probate Litigation April 27, 2026
In a contentious probate matter involving a disputed deed to residential property, our client, the administrator of the estate, seeks to recover assets after the deed was recorded by the decedent’s neighbor.
Major life events, shifts in financial status, and changes in the law can affect your estate plan.
By Heather A. McCollum and Gabriel P. Kokoszka April 14, 2026
Major life events, shifts in financial status, and changes in the applicable law can all affect your estate plan, and those changes may require you to make some edits to your documents. So, this spring, dust off your estate plan and consider the following 8 circumstances that signal an update is needed.
IRS Announces Filing Season is Progressing Smoothly
By Timothy M. Hughes April 10, 2026
The Internal Revenue Service recently announced that it is seeing the 2026 filing season have a rise in tax refunds. With the April 15th deadline approaching, the IRS stated that there is a smooth pace at which taxpayers are getting their refunds, with the high use of electronic filing.
Join our session to learn legal tips for successfully launching or growing a business!
By Lavelle Law April 3, 2026
Launching or growing a business? Don’t get tripped up by the legal stuff that can make or break you. Join us for this free seminar on May 13, 2026, and learn key legal tips for entrepreneurs.
Experienced business attorney Kerry Lavelle breaks down the three main avenues for buying a business
By Kerry M. Lavelle March 24, 2026
Thinking about buying a business? There’s more than one way to do it, and choosing the right path can save you time, money, and headaches. In this video, experienced business attorney Kerry Lavelle breaks down the three main avenues for buying a business, along with the pros and cons of each.
Lessons from the Chance the Rapper Manager Dispute
By Anthony V. Letto March 19, 2026
A lawsuit involving Chance the Rapper and his former manager, Pat Corcoran, highlights a costly lesson for businesses, creatives, and entrepreneurs alike: handshake deals can lead to million-dollar disputes.
Lavelle Saves Client $330K with Strategic Timing and Collaboration
By Tax Group March 18, 2026
Our client was haunted by non-dischargeable federal tax liabilities of over $400K from a business venture. After strategic timing and working with our Bankruptcy team, $330K was written off by the IRS before we filed Chapter 7 for the client, and he suffered no adverse results from the four-month delay.
Join Lavelle Law on April 9, for our Business After Hours!
By Team Lavelle March 13, 2026
Play Ball with Lavelle Law on April 9! Step up to the plate and join our annual Business After Hours event, hosted in the friendly confines of our Schaumburg office. Bonus points: Feel free to rock your favorite baseball team’s gear and show off your fandom while you’re at it! Free event for SBA members!
IRS Announces its Dirty Dozen Tax Scams for 2026
By Timothy M. Hughes March 10, 2026
The IRS announced its annual Dirty Dozen list of tax scams for 2026 that threaten the tax and financial information of taxpayers, businesses, and tax professionals. The Dirty Dozen is part of a broader campaign conducted by the IRS to educate taxpayers about identity theft schemes and other forms of fraud.
More Posts