Earlier quoted context omitted.
I used to be the IT Director for a document scanning business in the UK. Scanning paper HR records was the single most painful job we had to do. The entire file became a complete legal nightmare purely because it stopped being paper and became covered by Data Protection. Usually the HR department had to go through every single employee file and shred any documents that might be grounds for legal action before they go…
That sounds like "working as intended" - after all, if instead of just requesting their file the employee had initiated legal action against you, it would have been illegal to destroy those documents. And it also raises the question of which part of your HR process is generating incriminating documents in the first place?
Not our HR process, our customer's. What was actually destroyed depended on their interpretation of the law.
One common one was the Data Protection requirement to not keep inaccurate data meant that all but the latest employee change of address forms had to be destroyed. Easy to implement post-scanning, pain in the arse to do pre-scanning.