on-site OFCCP audit

mushroomHR

Does anyone know if during an on-site OFCCP audit they can ask to see the contents of employees' files? Specifically, we're wondering if they are allowed to have access to employee evaluations or other such documentation. Thanks.

Don D

They have a right to see the following: Your current and past three AAPs. Your applicant tracking log and related data. A copy of your organizational chart if you have one. Copies of newspaper advertisements you have run. Records you have proving you listed your openings with a Job Service office. Copies of your internal notices of openings and promotional opportunities. The applications and self disclosure documents of those applying including those hired. Vets-1 report. Any postings or other materials you might have showing you to be an EOE.

They do not have a right to inspect your personnel files, OSHA records, comp files, medical files, FMLA documents, I-9s or Training records.

They can also ask to speak with representative samples of employees, i.e. minorities, disabled, veterans.

Gillian3

Yes. They will do what they call a cohort analysis. They compare employee's who they consider to be somewhat equal in terms of experience and qualification, by race and sex, in order to determine whether their progress in the company is somewhat similar. They will also compare employees and applicants in terms of qualifications and ask why the person who was hired was, and the ones who weren't weren't. I don't remember an auditor asking about performance appraisals but I expect that they looked for them and if not there, would ask why.