Annual Records Retention Review Guideline

Purpose

To give departments a simple, repeatable process for reviewing the records they hold each year and destroying what is no longer needed — so files stay organized, storage costs stay down, and records that must legally be retained are not disposed of by mistake.

Scope

Applies to all Company records, in any location or format — paper files, shared drives, email, and other electronic storage. It does not apply to an employee's personal documents (for example, personal legal papers) that happen to be kept at a Company location.

Roles and responsibilities

HR / Records Management / Legal

• Maintain a current Records Retention Schedule specifying how long each type of record must (or may) be kept, based on legal, tax, and business requirements.
• Distribute the applicable retention schedule to department heads annually.

Department heads / unit managers

• Ensure the annual review takes place for records maintained in a central unit or department file.
• Confirm destruction is documented (see Procedure, step 4).

Employees

• Review any records they maintain, on the schedule below.
• Follow the Records Retention Schedule when identifying what can be destroyed.
• Keep remaining active files organized and secure.

Procedure

1. Annual review. Each January, employees and department heads review the records maintained in their central unit or department files.
2. Destroy what has expired. Destroy records that are past the retention period set in the Records Retention Schedule for that record type. Always check the schedule first — do not rely on a flat default period, since federal minimum retention periods differ considerably by record type and are frequently much longer than one year. For example (confirm current figures with Legal/HR before relying on them): EEOC/Title VII personnel and employment records generally must be kept at least 1 year from creation or the personnel action, whichever is later (29 CFR 1602.14); ADEA payroll records generally at least 3 years, with most other ADEA-related personnel records at least 1 year; FLSA payroll records at least 3 years (29 CFR 516.5) and supporting time/wage-computation records at least 2 years (29 CFR 516.6); Form I-9 records for 3 years after the date of hire or 1 year after termination, whichever is later; and ERISA plan-related records (Form 5500 filings, plan documents, and related compliance records) generally at least 6 years. These are floors, not ceilings — many record types must be kept longer once a claim, charge, audit, or litigation is reasonably anticipated (see the legal-hold override below), and some states impose longer minimums than these federal baselines.
3. Do not destroy records that must be preserved, including:

• Records subject to a longer statutory retention period.
• Records needed for a pending or reasonably anticipated audit, claim, investigation, or litigation (a "legal hold" — check with Legal/HR before destroying anything if you are aware of a hold).

1. Certify completion. Confirm in writing (email is sufficient) to your department head or HR that the review was completed and what was destroyed, in general terms.
2. Secure what remains. Keep active and retained files in a secure location, with access limited to those who need it.

Federal minimum retention periods

The table below summarizes federal minimum retention periods by record type, for reference alongside the Records Retention Schedule. It is not a substitute for the Records Retention Schedule maintained by HR/Records Management/Legal, which controls and may specify longer periods based on state law or business need.

Type of record	Years to keep
Hiring and personnel action information
Job applications, resumes, and other replies to advertisements	1 year from date of record (2 years recommended)
Records relating to refusal or failure to hire, including test papers, medical tests, and other screening tools	1 year from date of record (2 years recommended)
Job orders submitted to an employment agency or labor union	1 year from date of record (2 years recommended)
Advertisements or notices to the public or employees about openings, promotions, or training opportunities	1 year from date of record (2 years recommended)
Records showing the impact of employment actions on protected groups, including selections, promotions, demotions, layoffs, recalls, terminations, transfers, and training or overtime opportunities	1 year from date of record (2 years recommended)
Compensation program information
Documents concerning merit or seniority systems	2 years
Explanations of wage differences between employees of opposite sex	2 years
Job evaluations and job descriptions	2 years
Wage rate tables	2 years
Collective bargaining agreements and individual employment contracts	2 years
Benefits program information
Records supporting disclosures required in reports to the IRS, Department of Labor, and Pension Benefit Guaranty Corporation	6 years from date report filed
Plan description	1 year from termination of plan
Basic employee data
Name, address, SSN, gender, and date of birth	4 years following last action
Occupation and job classification	4 years following last action
Work authorization and work permits for minors	4 years following last action, or 1 year from termination
Form I-9	1 year from termination, or 3 years from hire, whichever is longer
Compensation
Daily work schedule	3 years from last action
Pay rate	3 years from last action
Weekly compensation	3 years
Amounts and dates of actual payment; period of service covered	4 years
Daily and weekly hours	4 years
Straight time and overtime hours and pay	4 years
Annuity and pension payments	4 years
Accident and health plan payments	4 years
Fringe benefits paid	4 years
Tips	4 years
Deductions and additions	4 years
Tax records
Amounts of wages subject to withholding	4 years
Agreements with employee to withhold additional taxes	4 years
Actual taxes withheld and dates withheld	4 years
Reasons for any difference between total tax liability and actual tax payments	4 years
Withholding form (W-4)	4 years
Employment actions
Dates hired, separated, rehired, resumed, and reason for separation	1 year from date of action
Promotions, demotions, transfers, layoffs, recalls, and training opportunities	1 year from date of action
Aptitude, ability, medical, or other tests used in employment actions	1 year from date of action
Polygraph test results and records, including reasons for administering	3 years from date of action
Health, medical, and safety data
Job-related injuries and illnesses	5 calendar years after the record is made
Requests for accommodation of disability	1 year from last action

These are federal minimums only — many record types must be kept longer once a claim, charge, audit, or litigation is reasonably anticipated (see the legal-hold override below), and some states impose longer minimums than these federal baselines. Confirm current figures and any state-specific requirements with Legal/HR before relying on them.

Legal hold override

If Legal or HR has issued a legal hold notice covering a record, that record must be preserved regardless of the general retention schedule or this annual review, until the hold is formally lifted.

References

• Records Retention Schedule (maintained by HR/Records Management/Legal)
• Human Resource Records Policy
• Information Security and Access Control Policy