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Personnel File

Anonymous - Aug 06, 2021
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Our company is a federal contactor and I am trying to understand our responsibilities regarding record keeping requirements for ’employment application’ that was completed by employees during their non-completive promotional process? For context, some of our internal openings are filled through the competitive selection process where employees will complete an ‘application form’ to be considered for the position and/or sometimes employees may decide to apply for a position that is posted externally and the Company ends up hiring that internal candidate. In terms of what the OFCCP would want and/or expect to see as part on an audit, do we need to keep them (application) in the respective personnel file with the initial application (when the employee was first hired to the company)?

1 Answer

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Ahmed Younies

President and CEO, HR Unlimited, Inc.

Alissa Horvitz, Esq.

Member Attorney, Roffman Horvitz, PLC

Allen Hudson, PHR, SHRM-CP

CEO, HudsonMann

Beth Ronnenburg, SPHR, SHRM-SCP

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Bill Osterndorf

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Carey Freitag

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Carla Irwin, Esq.

President, Carla Irwin & Associates, Inc.

Craig Leen

Board Member, Circa

David Cohen

President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Julia Mendez Achee

Senior Consultant - EEO/Affirmative Action Division, Biddle Consulting Group

Lisa Kaiser, Esq.

Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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