OFCCP Directive - Recordkeeping

Electronic Recordkeeping

In light of the transition to solely electronic recordkeeping systems, the OFCCP published a new directive regarding electronic recordkeeping in May of 2008. The timeframe required for keeping files and the correct way to convert and store files were reviewed during the OFCCP’s Homestretch webinar conducted on September 10th, 2008.
The record retention periods according to Executive Order 11246 are as follows: If you are a contractor with 150 or fewer employees, or do not have a contract of at least $150,000, the record retention period is a minimum of one year. Any contractors that employ over 150 employees or have a contract greater than $150,000, must keep their records for a minimum of two years. These regulations have not changed and are not new.
All paper records can be converted to an electronic format if the medium used accurately reproduces the paper original and would constitute a duplicate or substitute copy of the original paper record under Federal law. The records also need to be accurate and must be able to be converted back into a legible and readable paper copy available to be provided, should the OFCCP request them.
Original paper records may be disposed of following the complete transfer to the electronic format, only if the electronic file accurately reproduces the original paper records. Contractors that use the electronic system must keep their files accurate, accessible, and complete for the minimum record retention timeframe.