How Texas agencies should organize personnel records, prepare for OTRR, and manage the employment-record lifecycle.

TCOLE has introduced the OpenText Records Repository (OTRR) as its statewide confidential employment-record sharing system. The useful question for a Texas agency is how to build and maintain personnel records throughout employment so it can handle OTRR separation uploads and later background-record requests.

A small Texas police department should care because these responsibilities do not wait for a dedicated HR or compliance staff. The work often belongs to the chief, an assistant chief, a TAC, a training coordinator, or an administrative employee who already has several unrelated jobs.

OTRR did not create those personnel-file, hiring, and misconduct obligations. The model policies and commission rules set the underlying requirements. OTRR is how applicable records are now submitted and shared.

The easiest time to prepare an officer's personnel file is while the officer is still employed—not thirty days after separation.

OTRR at a glance

These points reflect current official TCOLE OTRR materials reviewed in September 2026. They are a starting orientation, not a substitute for current TCOLE rules, model policies, or OTRR instructions.

Understand the personnel-record system TCOLE expects

"The personnel file" is not one folder of every document associated with an officer. TCOLE's Preparing for OTRR guidance organizes records into four categories: Personnel (A-File), Department (G-File), TCOLE Credentialing Files, and Other Agency Files. That structure already existed in the Personnel Files model policy and Occupations Code § 1701.4535. OTRR uses the same categories.

OFFICER RECORDS
+-- Personnel / A-File
+-- Department / G-File
+-- TCOLE Credentialing Files
+-- Other Agency Files

Personnel File - A-File

The Personnel Files model policy and Occupations Code § 1701.4535 define the personnel file as three kinds of records: (1) a letter, memorandum, or document relating to a commendation, congratulation, or honor bestowed on the license holder by a member of the public or by the agency for an action, duty, or activity that relates to the license holder's official duties; (2) misconduct by the license holder if the document is from the employing agency and resulted in disciplinary action; and (3) the periodic evaluation of the license holder by a supervisor. 37 TAC § 211.29 requires the chief administrator to maintain that file for each appointed licensee and to submit a complete copy after separation.

If a negative letter, memorandum, document, or other notation of negative impact is included, the Personnel Files model policy requires notice to the license holder and gives the license holder 30 days after receipt to file a written response. The license holder is also entitled, on request, to a copy of any document placed in the file.

Department File - G-File

The department file holds information outside the personnel-file definition. A letter, memorandum, or document relating to alleged misconduct may not be placed in the personnel file if the agency determines there is insufficient evidence to sustain the charge. The model policy says that file should be marked "Designated as Confidential for Statewide Employment Database under Texas Occupations Code § 1701.168." 37 TAC § 211.29 requires the chief administrator to maintain a department file for each appointed licensee and to submit both the personnel file and the department file to TCOLE upon request as part of an ongoing investigation relating to the licensee.

The agency may not release department-file information to another agency or person without the license holder's written permission, unless Occupations Code § 1701.451 requires the release. A hiring law-enforcement agency is entitled to view the department file as that statute provides.

TCOLE Credentialing File

Credentialing records are created at hiring and appointment. Later hiring agencies may need them. They are not automatically CSED personnel-file uploads. The Classification Quick Reference shows where current TCOLE materials place each document, including where Preparing for OTRR and the file-type matrix use different labels for the same record.

Other Agency Files

Other Agency Files are documents the city or county retention schedule still requires. Uploading to OTRR does not replace those obligations. Keep a written inventory of local HR, payroll, medical, leave, and other employment records that are not A-File, G-File, or credentialing records.

Build the file throughout the officer's employment

Records accumulate from the first application through training, evaluation, assignment changes, and-when they occur-misconduct and discipline. Create each record when the work happens, classify it, and keep it retrievable.

HIRE  ->  CREDENTIAL  ->  TRAIN  ->  EVALUATE  ->  MAINTAIN  ->  SEPARATE  ->  SHARE

Appointment and hiring

Agencies were required to adopt TCOLE's Hiring Procedures model policy, or a substantively similar policy, by June 1, 2025, and submit it to TCOLE. The policy requires a completed Personal History Statement and written consent before the agency reviews background-investigation information.

It also requires a thorough background investigation, including personnel files and other employee records from each previous law-enforcement employer; documentation of the investigation; review of files electronically or in person, not by phone; and completion of applicable appointment and credentialing records. See TCOLE's Hiring Procedures model policy for the current investigation-source list.

That policy uses "personnel file" more broadly than the Occupations Code A-File definition. For OTRR classification and sharing, follow the current TCOLE file-type matrix rather than the hiring-policy folder name.

Training and field training

Training, FTO, probationary, and remedial records are maintained; they are not automatically A-File or CSED documents. Firearms qualifications typically belong with credentialing records. A later hiring agency may still ask for them.

Performance and employment changes

Periodic evaluations and qualifying commendations or honors relating to official duties belong in the A-File, with any licensee response. Employment-change records may belong in the department or other agency file. They remain subject to retention and, on request, sharing rules.

Misconduct and discipline

Agencies were required to adopt TCOLE's Misconduct Allegations model policy, or a substantively similar policy, by June 1, 2025. Investigate allegations of misconduct that may result in suspension, demotion, or termination when the agency becomes aware of them. TCOLE's misconduct FAQ says administrative investigations should generally be completed within 180 days or within 30 days of separation, whichever occurs first, absent other applicable laws, agreements, or policies. Separation does not terminate that investigation duty. 37 TAC § 211.29 restates the chief administrator's duty to complete the investigation after separation.

Starting June 1, 2025, the agency submits a completed administrative investigation to TCOLE on the Misconduct Investigation Report (MIR), whether the allegation is sustained or not. If criminal charges are filed, submit the Criminal Charges Notification (E-1) within 30 days after the criminal investigation is completed. If findings or discipline are appealed, notify TCOLE and report the appeal disposition within 30 days after receiving the decision.

The MIR is a TCOLE submission, not a substitute for the investigation file. Sustained misconduct that resulted in disciplinary action belongs in the A-File; alleged misconduct that is not sustained does not. Preparing for OTRR also lists MIRs among credentialing records; use the current TCOLE upload path.

Prepare for separation before the officer leaves

The clock starts when the license holder separates. Current OTRR FAQs require the personnel file-and the MIR-to be uploaded within 30 calendar days. That CSED upload is the defined personnel file plus MIRs, not the entire employment file. Agencies may upload those records during the appointment. TCOLE does not prescribe the internal sequence below; it does prescribe the submission duty.

SEPARATION
        |
Confirm separation information
        |
Review the officer's files
        |
Identify records subject to TCOLE submission
        |
Confirm the documents are complete
        |
Upload through OTRR
        |
Confirm submission
        |
Preserve agency copies under the applicable retention schedule

37 TAC § 211.29 requires electronic notice to TCOLE when a person under appointment resigns or is terminated, following Occupations Code § 1701.452, and submission of a complete copy of the personnel file in a manner prescribed by TCOLE. Current OTRR materials identify OTRR as that manner for applicable personnel-file and MIR uploads. The personnel-file upload requirement is not retroactive: current FAQs say agencies are only expected to upload files for license holders separating now and in the future. If a later hiring agency requests records, the responding agency still has to produce what it retained.

Missing or nonexistent records

If the licensee does not have a personnel file, current OTRR FAQs say to upload a memo explaining that. Do not invent a substitute packet. If a required document does not exist, the memo should say so. If it exists elsewhere, find it and classify it. Follow TCOLE's current Records Division procedure to correct an erroneous upload.

Respond when another agency is hiring your former officer

Outgoing: another agency requests records about your former officer. Incoming: your agency is investigating someone it may hire.

Responding agency

File Uploaders respond to record requests. Current OTRR FAQs give the responding agency 10 calendar days. The requesting agency uploads the applicant's signed Authority to Release Information with the request. Records are not provided automatically.

On a hiring-agency request, the rest of the responsive files go to Secure Share. Current TCOLE file-type guidance says agencies may not withhold those Secure Share-type records based on a non-disclosure agreement if they received a signed authorization.

The Hiring Procedures model policy tells a requesting investigator that if a release was provided and an agency does not respond within ten business days, and the investigator has made direct contact, the investigator should contact the TCOLE Field Service Agent. That is hiring-policy escalation guidance. It does not replace the OTRR FAQ's 10-calendar-day deadline for the responding agency.

Hiring / background agency

Background Investigators request licensee files from prior agencies. Obtain the Personal History Statement and written consent, upload the Authority to Release Information, then request and review the records. People who have never held a TCOLE license or been appointed will not be in OTRR.

Document the investigation in a background investigation report. Review files electronically or in person, not by phone. Downloaded records become the requesting agency's records and are subject to that agency's retention schedule.

Make the process sustainable for a small agency

Name the work and assign the OTRR roles TCOLE uses.

Assign the OTRR roles

File Uploaders upload personnel files and respond to investigator requests. Background Investigators request and review prior-agency files. CSED Uploaders handle confidential statewide employment-database files; Secure Share Uploaders handle the temporary documents requested for background investigations. Users may hold more than one role. The chief administrator or a delegate assigns those roles in the Assignment Status Manager and remains accountable for the deadlines.

Decide who owns each step

Ownership should be explicit. In a small agency, one person may hold several functions.

Digitize and organize before you need the records

Digitizing records makes retrieval and transmission easier; it does not replace retention requirements.

Turn the requirements into a repeatable personnel-file process

Use the checklist and classification reference to run the process. Do not treat them as a second copy of TCOLE's rules or file matrix.

TCOLE Personnel File & OTRR Readiness Checklist

A practical readiness checklist for Texas law-enforcement agencies. Confirm that records are being created and placed in the appropriate TCOLE category. Do not treat every item as an A-File document or as a single OTRR upload.

Agency setup

• Confirm the current TCOLE Personnel Files policy has been adopted, or the agency has an approved substantively similar policy, as required (agency adoption date June 1, 2025).
• Confirm the current Hiring Procedures policy, or a substantively similar policy (agency adoption date June 1, 2025).
• Confirm the current Misconduct Allegations policy, or a substantively similar policy (agency adoption date June 1, 2025).
• Confirm adopted policies were submitted to TCOLE / the Field Service Agent as current TCOLE guidance requires.
• Identify agency File Uploader(s), including CSED Uploader and Secure Share Uploader assignments as applicable.
• Identify Background Investigator(s).
• Confirm required TCOLE Login Hub access for each assigned person.
• Confirm applicable Assignment Status Manager assignments in TCLEDDS, and confirm that assigned users can successfully access OTRR before they are needed.
• Confirm each assigned user has a PID and a TCLEDDS association as licensed or non-licensed staff.
• Identify who oversees personnel-file compliance. The chief administrator remains accountable.
• Document backup responsibility for uploads, background requests, and role assignment.

File structure

• Personnel / A-File established for each license holder.
• Department / G-File established for each license holder, marked as current TCOLE policy requires.
• TCOLE Credentialing File established.
• Other Agency Files identified as required by the local retention schedule.
• Existing documents reviewed for correct classification under current TCOLE categories.
• Restricted / non-shareable records identified, including CCH/fingerprint returns and proof of citizenship.
• Local retention requirements documented. Uploading to OTRR does not replace them.

During employment

• Appointment and hiring records created and filed in the appropriate category (application, PHS, consent/release, background investigation, interview materials, appointment forms).
• Credentialing documents maintained where applicable (L-1/L1-T, L-2, L-3, F-5R, BCF, NDI documentation, court documents).
• Training, FTO, probationary, and remedial-training records maintained in the training / department category-not assumed to be A-File documents.
• Periodic evaluations completed and placed in the A-File, including any licensee response.
• Commendations and awards placed in the A-File.
• Firearms qualifications maintained in the credentialing file as applicable.
• Employment-change records (promotion, demotion, assignment or pay change, performance-improvement plan) filed in the category current TCOLE guidance uses.
• Misconduct allegations investigated under the adopted Misconduct Allegations policy, including after separation when an investigation is pending.
• Completed investigation documentation placed in the A-File or G-File, as appropriate.
• Final disciplinary actions for suspension, demotion, or termination placed in the A-File, with required notice and any licensee response.
• MIRs prepared and available for timely TCOLE / OTRR submission. Current OTRR guidance allows upload during the appointment.
• CCH/fingerprint returns and proof of citizenship retained as required locally and excluded from OTRR sharing.

At separation

• Confirm the separation date. The 30-calendar-day OTRR / TCOLE personnel-file deadline runs from separation.
• Complete any pending misconduct investigation. Separation does not end that duty.
• Review the Personnel / A-File for commendations, evaluations and responses, final disciplinary actions and responses, and MIRs.
• Confirm required documents are complete. If the licensee has no personnel file, upload a memo explaining that, as current OTRR FAQs require.
• Identify the applicable TCOLE / OTRR CSED submission records. Do not treat the entire employment file as the CSED upload.
• Upload required personnel-file records and MIRs in OTRR within 30 calendar days of separation. Records may also be uploaded before separation.
• Submit required separation reporting to TCOLE under Occupations Code § 1701.452 / 37 TAC § 211.29.
• Confirm the OTRR submission.
• Retain agency copies according to the applicable city or county retention schedule.

When another agency requests records

• Verify the OTRR request and the assigned File Uploader responsibility.
• Confirm the required authorization / consent (Authority to Release Information).
• Identify responsive CSED and Secure Share records using the current TCOLE file-type matrix.
• Review for current TCOLE sharing requirements and restrictions. Do not share CCH/fingerprint returns or proof of citizenship.
• Upload or provide records within 10 calendar days of the request, as current OTRR FAQs require.
• Do not withhold applicable Secure Share-type records based on an NDA if a signed authorization was received, as current TCOLE file-type guidance states.
• Document completion.

When your agency is hiring

• Obtain the applicant's completed Personal History Statement and written consent / Authority to Release Information before reviewing employment records.
• Assign or confirm the Background Investigator role in the Assignment Status Manager.
• Identify prior appointing agencies, academies, and applicable TCOLE records.
• Upload the signed Authority to Release Information in OTRR and request records. Do not expect instant production.
• Review returned records within the current access window (opened files marked late after 14 days; Secure Share files available 60 days after creation).
• Review files electronically or in person. File review may not be done by phone.
• Document findings in the background investigation report and complete the current BCF / L-1 process.
• Complete remaining Hiring Procedures steps (medical and psychological examinations, fingerprint search, firearms qualification as applicable) before appointment.
• If a prior agency does not respond, follow current Hiring Procedures escalation, including Field Service Agent assistance after the policy's contact steps.

Personnel Record Classification Quick Reference

Classifications below come from TCOLE's current OTRR File Types and Folders matrix, Preparing for OTRR, and the Personnel Files model policy. They are not Thin Line categories. If TCOLE does not clearly classify an item, the table says to confirm with TCOLE or the current agency policy rather than guessing.

Build the file before you need the file

OTRR did not invent the personnel file. It made the file move.

The best separation workflow starts on the officer's first day.