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Sarbanes Oxley and Recordkeeping


I am revamping our recruitment process and need to know what we should be doing with regard to Sarbanes Oxley and employment.


As of June 1, 2005, you must properly dispose of any credit or consumer information that is kept for employees and/or job applicants or risk serious fines and penalties. So if, for example, you request any information from a consumer reporting agency, you must have a plan for how to dispose of the information in the future to avoid jeopardizing the identity (through identity theft) of your employees or applicants. A court could find you negligent if you do not store, distribute, and destroy your employment records in an “appropriate manner” and your files are stolen.

We found some wonderful information on this topic in the March 15, 2005 issue of HR Matters e-Tips at

In the article linked above, Personnel Policy Services elaborates on steps you can take to safeguard your employment records. In a nutshell:

  1. Limit access to employee files
  2. Be sure your files are locked
  3. Install and update firewalls on your computer
  4. Conduct background checks on all employees that will have access to sensitive information
  5. Remove access to sensitive material upon termination
  6. Do not use social security numbers to identify employees
  7. Destroy employment files that no longer need to be kept
  8. Assist your employees with identify theft protection measures

Recruitment isn’t just a matter of finding and hiring the right person. There are scores of regulations that must be adhered to or you risk fines or penalties. Strategic HR specializing in helping companies find, hire and retain a talented workforce while keeping an organization compliant. Visit our Recruitment page to learn how we can help you hire safely.