Recordkeeping violations continue to be the top violation during an OFCCP audit. These voluminous, and often cumbersome, requirements are intended to promote equal opportunity during a company’s hiring process. They can also promote confusion among unsuspecting employers, making them an easy target during an audit. To understand how such violations occur, and to prevent them from occurring, contractors first need to know how to identify what is considered a “record” for the purposes of an audit.

The OFCCP interprets the phrase “any personnel or employment records” broadly. It includes what can be considered the obvious:

  • documents, such as applications,
  • disciplinary actions,