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Run: Candidate Data Retention and Disposition SOP

This SOP defines how to retain applicant and candidate records, check holds, and dispose of files securely at the end of the retention period. It helps HR te...

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Steps

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.
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.
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.
The records custodian documents the hold status, notifies the compliance owner, and excludes the records from any destruction workflow until written release is received.
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.
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.
The designated records owner or compliance approver reviews the disposition log and authorizes destruction only after confirming the records are eligible for secure disposal.
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.
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.

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