Most employers meet this obligation for the first time on the day it is already a problem. The request rarely comes from the employee directly. It comes from a lawyer, it arrives before anything else does, and it is designed to find out what your file contains before you have thought about it.
Two separate rights are in play and they run on different clocks. Personnel records fall under Labor Code section 1198.5 with a 30 calendar day deadline. Payroll records fall under section 226 with 21 calendar days. Section 432 adds a third: anything the employee signed, they are entitled to a copy of. A single letter often triggers all three, and answering one of them is not answering the others.
What tends to be wrong is not the response time. It is the contents. Files are missing the documentation that sat between a good performance review and a termination. They contain medical information that should have been kept in a separate confidential file. They have I-9 forms filed inside them, or notes about an investigation involving other people, or a manager's private commentary written by somebody who never imagined the employee would read it.
The file you have on the day of the request is the file you have. A decision that was careful but undocumented reads, on paper, like a decision with no reason behind it.
What you can do
Decide now who receives a records request and what they do with it, so the first 30 day clock is not spent working out who is responsible.
Pull medical information, accommodation paperwork and anything disclosing a condition into a separate confidential file. Move I-9 forms out too.
Read three files of employees who have left in the last year, as if you were the lawyer who requested them.
Write down the retention period for each category of document, then check that anyone doing the filing knows it.
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