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Personnel File

Anonymous - Apr 14, 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

Our Experts

Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.

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

President, Berkshire Associates

Bill Osterndorf

President and Founder, HR Analytical Services

Carey Freitag

Human Resources Manager, Circa

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

Lisa Kaiser, Esq.

Managing Partner, 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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