As a federal contractor, UC San Diego is currently undergoing an audit by the Office of Federal Contract Compliance Programs (OFCCP), and it has come to light that some departments have not complied with campus and federal regulations regarding retention of past recruitment records.
This is an extremely important reminder that past recruitment materials cannot be discarded for a period of three to five years.
Use of AP On-Line Recruit has been mandatory since May 1, 2013, so recruitment records will automatically be maintained electronically going forward. However, departments are still required to retain records for recruitments completed outside Recruit prior to May 1. They are also required to retain any recruitment materials that may be received outside of Recruit in the future.
The UC San Diego Policy and Procedures Manual, Section 480-20.V.8, stipulates that complete and accurate records regarding each position, including applicant files, must be retained for a period of three to five years and are subject to audit by the director of the Office of Academic Diversity and Equal Opportunity at any time.
Further, OFCCP regulations stipulate that all federal contractors are required to maintain any personnel or employment records made or kept by them. These records include but are not limited t
· Job descriptions
· Job postings and advertisements
· Job applications and resumes
· Interview notes
· Tests and test results
· Written employment policies and procedures
· Records pertaining to hiring, assignment, promotion, demotion, transfer, lay-off, termination, compensation, and personnel files
OFCCP regulations state that, in general, records must be kept for two years from the date of making the personnel record or taking the personnel action, whichever is later. Note, however, that UC San Diego requires retention of these materials for a longer period.