Thank you for posting additional information. From an objective perspective, the only relevant question is the first one. If the applicant does not possess the required skills, then the company should not move forward. If it moves forward with an applicant that does not have the required skills, then those skills are not required for the job and should not be part of the screening process. A "good fit for the team" and "Does applicant values/goals align with company values/goals" cannot likely be adequately defined to survive an audit. The evaluation of an applicant should only be based on required elements for the job. There are a number of pitfalls in a situation like this, but it can be done well. It seems what you are trying to do is get a record of why the applicant was screened out during the interview, which is great. I recommend that you ensure your hiring team is properly trained (as required by the regulations) in the EEO obligations of the company and that each understands the Uniform Guidelines. Selection criteria that cannot be defined, such as "poor fit," should be avoided. The hiring team could certainly answer questions regarding what appropriate qualifications the individual did not possess. Let me know if you need more info.