Keeping recruitment records using e-Recruitment

Introduction

What is the e-Recruitment system?

E-Recruitment is a whole of government system used by many government agencies to manage the recruitment process. It is a cloud-based application delivered via the web.

E-Recruitment is a business system, which provides a workflow and structure for the recruitment process, and captures extensive data about the process and candidates. However, the system has limited recordkeeping capabilities and therefore cannot be relied upon for the retention of some records associated with the recruitment process and the selection of successful applicants.

While in the majority of cases it is suitable to retain most of your short term recruitment records in e-Recruitment, certain records relating to successful applicants must be exported to an agency’s own corporate recordkeeping system for retention as part of the ongoing management of their appointment and service.

Functionality of e-Recruitment

E-recruitment offers the following basic functionalities:

creates vacancy and position details
generates advertisements
uploads generic and customised position descriptions
gives access to applications, interview schedules, short lists, and panel assessments
workflows approvals
generates related correspondence
tracks progress and results, and
produces whole-of-government reports.

A selection report can be generated at the conclusion of a recruitment action. Providing all the information has been correctly entered into the system, this will be a summary record of the process. This can be retained either electronically within e-Recruitment or in hard copy, with or without handwritten signatures, depending on the agency's requirements. A similar report is available in e-Recruitment for the shortlisting or cull phase of the selection process.

Recordkeeping requirements for recruitment processes

There are a number of important reasons why agencies must keep full, accurate and reliable records of recruitment processes. For example, these records may be required for:

dealing with appeals against recruitment decisions
assisting employees in confirming their rights and entitlements, or
managing the details of applicants held in 'reserve' via eligibility lists.

Your agency needs to make a conscious, risk-based decision about how its different recruitment records will be managed i.e. which records can be managed in e-Recruitment and which records should be exported to the agency’s own recordkeeping system.

Storage of records 'in the cloud'

The e-Recruitment system is an online application, with the information it captures and manages not stored in ‘in-house’ servers within each agency but rather in the cloud (in the United States) by the software provider on behalf of the NSW Government.

The Public Service Commission has a negotiated whole-of-government contract with the e-Recruitment service providers Taleo. This means that each agency does not need to negotiate a separate contract with the service provider.

The Public Service Commission has also considered the general risks associated with the e-Recruitment system in order to meet the requirements of the General authority for transferring records out of NSW for storage with or maintenance by service providers based outside the State. Individual agencies may have additional risks associated with the use of cloud-based systems that should be assessed and mitigated.

In addition, the table below outlines some of the system risks and mitigation strategies adopted by the Public Service Commission.

Risk	Likelihood	Impact	Mitigation
Data held in multiple jurisdictions	LOW	LOW	Data is stored in the United States only
Asset ownership is unclear	LOW	LOW	The Government owns the data on behalf of the agencies. Taleo retains the intellectual property rights to the software
Audit management processes are not robust	LOW	LOW	All changes are logged and auditable
Backup management is not adequately defined and a robust backup process is not in place or not followed	LOW	MEDIUM	Transaction Logs are backed up every 4 hours, twice weekly block level incremental backups are taken and weekly full system backups are taken, encrypted using AES128 and vaulted offsite for three years
Data and hardware not secure	LOW	HIGH	24/7 managed facility 24/7/365 security presence CCTV coverage (Archived for 60 days) No unescorted access Multiple layers of electronically controlled card access Multiple Biometric scanners control access Up-to-date master list of authorised employees Equipment in caged environment, individual locked cages, cabinets and suites An audit trail of changes to information is maintained in e-Recruitment
Data is not retained for the legislated time period	LOW	LOW	Taleo has adopted its Production Data Management Policy. This policy shows that Taleo will allow up to seven (7) years worth of data in its Production environment for each customer and keeps backups for up to three (3) years. Data that must be retained beyond 7 years for successful candidates are to be exported on completion of recruitment action to the relevant agency’s recordkeeping system
Electronic data of a successful candidate is retained in e-Recruitment as well as being held in agency recordkeeping system, resulting in no single 'source of truth'	LOW	LOW	Duplication (of exported information about the successful candidate) would only occur for 7 years, prior to purge System security, audit trails etc would prevent change to these records within e-Recruitment System security, audit trails etc in the agency’s recordkeeping system would prevent change to the exported records. Agencies should have business rules in place to use this version for future business action
Loss of visibility to an agency of the recruitment outcome and inability to reconstruct the original order of the recruitment process should data be deleted when a successful applicant's record is exported to the agency recordkeeping system	HIGH	HIGH	Retain information in e-Recruitment for 7 years and link with metadata to agency recordkeeping system
An agency will not have the ability to access a complete employee personnel file	LOW	LOW	Export successful candidate information to the agency's recordkeeping system

What e-Recruitment can and cannot do

E-Recruitment does not comply fully with the requirements of State Records’ Standard on Records Management. However, e-Recruitment does have some standard, basic recordkeeping controls (e.g. the ability to capture read-only records, provide security and audit trails etc).

In the majority of cases the basic controls within e-Recruitment should be sufficient for the management of short term records of the recruitment process. Most records only need to be retained for 2 years after recruitment has been finalised, and the e-Recruitment system can manage this. If the agency is concerned that the risks to these short term records are still too great, they should determine an alternative means of capturing these records e.g. exporting them to the agency’s recordkeeping system.

The e-Recruitment system cannot adequately maintain records of the recruitment process that have long term retention requirements. Records of the successful candidate required for ongoing management of their appointment and service must be extracted from the system and saved and managed within the recruiting agency’s records management system. This export should occur at the step of ‘Notification’ and a status of ‘Hired.’

Disposal of records

Many records created and received as part of recruitment actions are only required to be retained for relatively short periods of time. This would include advertisements, selection committee records, applications from unsuccessful applicants etc.

However, other records such as applications and certain background checks for successful applicants are generally required to be retained for at least 7 years after employment ceases. Typically, these records are placed on or maintained as part of the individual’s personal file/record of employment/service history. These records must therefore be exported out of e-Recruitment and managed in the agency’s records management system.

Requirements for the retention and disposal of personnel records including records of recruitment actions are contained in the General retention and disposal authority: administrative records. A summary of these requirements in relation to recruitment records in e-Recruitment is provided below.

Purge of e-recruitment data

The Public Service Commission has advised State Records that, at this stage, it plans to purge data of completed recruitment action from the e-Recruitment system every 7 years. As a result, any records required to be retained beyond this period must be exported post successful recruitment action.

Duplication of records

As purges only occur every 7 years, for this period there may be duplication between the content in e-Recruitment and the recruitment records held in your agency’s recordkeeping system.

Once the successful applicant’s records are transferred into your recordkeeping system, they should be considered to be the authoritative record for any future business. The version contained in the e-Recruitment system should be considered as a copy and not used for any further reference or future business action.

Examples of recruitment records and advice on their management

The examples provided below are based on consultation with a sample of agencies using the e-Recruitment system. The recruitment records generated by your agency may differ in content or names. Please refer to the General retention and disposal authority: administrative records (GA28) to determine disposal classes for your records, or contact State Records.

Note: The recordkeeping advice provided in these tables is general only and does not take into account specific requirements and risks that some agencies may be subject to. If additional risks exist, owing to the nature of the business, these should be assessed by the agencies when determining recordkeeping practice.

Examples of recruitment records	Disposal class and retention in the General retention and disposal authority: administrative records	Recordkeeping advice
Some agencies keep records documenting the internal approval to commence a recruitment action	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	Details of who approved the recruitment and when are recorded and can be locked down in the e-Recruitment system. This information is managed using User IDs. The full record of internal approval can be attached to the appropriate requisition in the e-Recruitment system or kept in the agency’s recordkeeping system for the required retention period.
Copy of the job advertisement	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	A locked down version of the job advertisement is not able to be captured by the system. Agencies should print to PDF the job advertisement as it appeared on jobs.nsw and capture this along with the requisition.
Record of the selection panel members	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	The Convenor and other members of the selection panel are recorded in the e-Recruitment system. The details are time and date stamped and notes showing panel members decisions on candidates are read-only.
Culling report	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	If the e-Recruitment system is used correctly, all steps and comments regarding shortlisting, including reasons, will be recorded.
Records of any reference checks carried out	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	Information regarding the completion of reference checks is included in the selection report for the successful candidate (see below).
Selection report	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	If the e-Recruitment system has been used correctly, all steps and comments regarding the interviews, referee checks and recommendations, including reasons, will be recorded.
Declaration on conflict of interest	15.10.1 – Retain for a minimum of 2 years after recruitment has been finalised, then destroy	This is recorded in e-Recruitment via communications between panel members and the panel chair/'Owner'.
Eligibility list (also known as the e-List)	15.10.1– Retain for a minimum of 2 years after recruitment has been finalised, then destroy	The Selection Report shows all the necessary recruitment details for successful and eligibility listed candidates. The Eligibility List report shows requisition (job) titles with the eligible candidates' names against them.
Applications that were received and copies of the letters that were written to the successful and unsuccessful applicants.	Successful applicants – 15.4.3 - Retain for a minimum of 75 years from date of birth or 7 years after employment ceases, then destroy Unsuccessful applicants – 15.10.1 Retain for a minimum of 2 years after recruitment finalised, then destroy	Unsuccessful candidate records can be retained as ‘read only’ within each Candidate file. Successful candidate records should be exported to an agency recordkeeping system where they can be managed long term. This should happen at the e-Recruitment step of 'Notification' and a Status of 'Hired'.

Records of background checks

Examples of recruitment records	Disposal class and retention period in the General retention and disposal authority: administrative records	Recordkeeping advice
Criminal record checks	15.10.2 – Records detailing a person’s criminal record provided in response to a criminal record check (ie Police reports) - Retain until check completed, then destroy	The selection report contains a checklist that the check has occurred, and that the candidate has been successful at a particular date/time. The selection report will be retained for the required 2 years after recruitment has been finalised. Agencies need to assess for their own purposes whether they need to retain evidence of a check being carried out for longer periods. No details of an individual’s criminal history provided in response to a criminal record check should be recorded or maintained within the e-Recruitment system. In addition, any details of an individual’s criminal history provided in response to criminal record checks, and any further internal assessment or follow up with the individual regarding their eligibility for appointment, should be kept under secure arrangements with only limited access from authorised officers. Details of criminal records should be destroyed 'within six months of the last action being taken on them.' (NSW Government Personnel Handbook, 2-15.5.1).
Working with children checks	5.10.1 - Records of working with children checks as a result of which a job applicant is not offered employment - Retain for a minimum of 2 years after recruitment is finalised, then destroy 15.4.3 - Records relating to working with children checks as a result of which: a job applicant is offered employment an existing employee is determined fit to work with children an existing employee is determined unfit to work with children. Retain for a minimum of 75 years after the date of birth of employee, or 7 years after action completed, whichever is later, then destroy	The selection committee report contains a checklist that the check has occurred, and that the candidate has been successful at a particular date/time. No details of an individual’s criminal history provided in response to a working with children check should be recorded or maintained within the e-Recruitment system. In addition, details of an individual’s criminal history provided in response to working with children checks, and any further internal assessment or follow up with the individual regarding their eligibility for appointment, should be kept under secure arrangements with only limited access from authorised officers.
Conduct and services check	Successful applicants 15.4.3 – Retain for a minimum of 75 years after the date of birth of employee or 7 years after employment ceases, then destroy Unsuccessful applicants 15.10.1 - Retain for a minimum of 2 years after recruitment finalised, then destroy	If this check is required, an agency can set this up as a 'Status event' in e-Recruitment. E-recruitment will then record the checks performed, by whom and when, for successful applicants and these details become read-only in the system. The selection committee report contains a checklist that the check has occurred and that the candidate has been successful at a particular date/time. No details from the outcome of a person’s conduct and services check should be recorded or maintained within the e-Recruitment system. Records of the outcome of an individual’s conduct and services check, or any further internal assessment or follow up with the individual regarding their eligibility for appointment, should be kept under secure arrangements with only limited access from authorised officers.

Examples of recruitment records

Disposal class and retention period in the General retention and disposal authority: administrative records

Recordkeeping advice

Criminal record checks

15.10.2 – Records detailing a person’s criminal record provided in response to a criminal record check (ie Police reports) - Retain until check completed, then destroy

The selection report contains a checklist that the check has occurred, and that the candidate has been successful at a particular date/time. The selection report will be retained for the required 2 years after recruitment has been finalised. Agencies need to assess for their own purposes whether they need to retain evidence of a check being carried out for longer periods.

No details of an individual’s criminal history provided in response to a criminal record check should be recorded or maintained within the e-Recruitment system.

In addition, any details of an individual’s criminal history provided in response to criminal record checks, and any further internal assessment or follow up with the individual regarding their eligibility for appointment, should be kept under secure arrangements with only limited access from authorised officers. Details of criminal records should be destroyed 'within six months of the last action being taken on them.' (NSW Government Personnel Handbook, 2-15.5.1).

Working with children checks

5.10.1 - Records of working with children checks as a result of which a job applicant is not offered employment - Retain for a minimum of 2 years after recruitment is finalised, then destroy

15.4.3 - Records relating to working with children checks as a result of which:

a job applicant is offered employment
an existing employee is determined fit to work with children
an existing employee is determined unfit to work with children.

Retain for a minimum of 75 years after the date of birth of employee, or 7 years after action completed, whichever is later, then destroy

The selection committee report contains a checklist that the check has occurred, and that the candidate has been successful at a particular date/time.

No details of an individual’s criminal history provided in response to a working with children check should be recorded or maintained within the e-Recruitment system.

In addition, details of an individual’s criminal history provided in response to working with children checks, and any further internal assessment or follow up with the individual regarding their eligibility for appointment, should be kept under secure arrangements with only limited access from authorised officers.

Conduct and services check

Successful applicants 15.4.3 – Retain for a minimum of 75 years after the date of birth of employee or 7 years after employment ceases, then destroy

Unsuccessful applicants 15.10.1 - Retain for a minimum of 2 years after recruitment finalised, then destroy

If this check is required, an agency can set this up as a 'Status event' in e-Recruitment. E-recruitment will then record the checks performed, by whom and when, for successful applicants and these details become read-only in the system. The selection committee report contains a checklist that the check has occurred and that the candidate has been successful at a particular date/time.

No details from the outcome of a person’s conduct and services check should be recorded or maintained within the e-Recruitment system.

Records of the outcome of an individual’s conduct and services check, or any further internal assessment or follow up with the individual regarding their eligibility for appointment, should be kept under secure arrangements with only limited access from authorised officers.

Acknowledgements

State Records NSW wishes to thank the following agencies for their assistance in the development of this advice: Department of Premier and Cabinet e-Recruitment team, Workcover NSW, Department of Education and Communities and Department of Finance and Services.

For recordkeeping advice please contact govrec@staterecords.nsw.gov.au.

First published 2010 / Revised 2011

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