Candidate Data Retention and Disposition SOP

Standard operating procedure for retaining applicant and candidate records for the required retention period and securely disposing of records in compliance with OFCCP, EEOC, and applicable state requirements.

Steps

• Records custodian confirms the retention trigger date
  The records custodian verifies the candidate record creation date, final disposition date, or other policy-defined trigger date against the applicable retention rule, then documents the trigger date in the disposition log before proceeding.
• Records custodian reviews applicable retention requirements
  The records custodian reviews the retention schedule, state law reference, and OFCCP/EEOC guidance, then records the longest applicable retention period for the candidate record set.
• Records custodian checks for legal holds or investigations
  The records custodian checks the legal hold register and case management log for any litigation hold, audit hold, complaint, investigation, or preservation notice, then records a yes/no eligibility decision for disposition.
• Records custodian escalates records under hold
  The records custodian documents the hold status, notifies the compliance owner, and excludes the records from any destruction workflow until written release is received.
• Records custodian verifies record completeness before disposition
  The records custodian confirms that required fields such as application data, interview notes, disposition reason, and any required demographic or compliance records are present in the candidate file before it is approved for destruction.
• Records custodian documents the non-selection or disposition reason
  The records custodian enters an objective, job-related disposition reason approved by HR and legal into the applicant tracking system so the record trail is complete and searchable.
• Records owner approves records for secure disposal
  The designated records owner or compliance approver reviews the disposition log and authorizes destruction only after confirming the records are eligible for secure disposal.
• Assigned operator destroys records using approved secure method
  The assigned operator destroys the candidate records using the approved secure method for the record medium, such as cross-cut shredding, secure pulping, or certified electronic wiping, and confirms the records are irreversibly destroyed.
• Records custodian records disposition evidence and retains the audit trail
  The records custodian files the certificate of destruction or other disposition evidence in the audit log, then retains the audit trail according to the records retention schedule.