To access the record retention details, you can read the details here. In summary, any personnel or employment record made or kept by the contractor will preserve it for a period of no less than two years from the date of making the record or the personnel action involved, whichever occurs later. However, if the contractor has less than 150 employees or does not have a government contract of at least $150K, the minimum record retention period is one year from the date of the making the record or the personnel action involved, whichever occurs later. “Such records include, but are not necessarily limited to hiring, assignment, promotion . . . resumes of job seekers who met the basic qualifications for the particular position who are considered by the contractor), regardless of whether the individual qualifies as an Internet Applicant under 41 CFR 60-1.3, tests and test results, and interview notes." Today's most common violations occur with recordkeeping practices, and because the regulation doesn't give detailed information about interview notes, it is important that training be provided to individuals who are conducting interviews for consistency as notes can be used later in legal matters. Generally speaking, the interviewer will take notes on each interviewee, but it needs to occur on a separate piece of paper - not on the resume or job application! Though it may seem obvious, notes should not indicate an interviewee’s gender, age, race, national origin, disability, etc. as it can be interpreted as discriminatory. Thus, the notes need to be objective in nature and based on the facts of the job.
You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.