Schedule No. 90 Personnel Records

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Issued: July 2012
Updated: November 2020

General Description: Records relating to the hiring, employment, workplace safety, benefits, compensation, retirement, and termination of employees.

No record may be destroyed under this General Retention Schedule without the approval from the Records Department and the City and County of Denver’s Records Manager. Additionally, no record may be destroyed if the record is subject to an active litigation hold (refer to Executive Order 143-C). For additional information about the records program or records retention refer to Executive Order 143-B. The Records Management Program Policies and Procedures Manual for instruction about records creation, management, and disposition of individual records. The minimum retention periods specified in this schedule apply to the information contained within the record, regardless of the format of the record (paper, microfilm, electronic, etc.). Each agency must decide on the format for retention of each type of record, ensuring authenticity, readability, and accessibility for the entire retention period. Duplicate copies are NOT records. Copies that are created for administrative, convenience, reference or other purpose are NOT records and should be retained only until no longer useful. Electronic Records and Data must remain accessible, authentic, reliable, and  through any kind of system change, update, or system end of life for the entire period of its retention, which shall be defined by information-type, as presented in this General Retention Schedule. Provided the data is an accurate representation of the information contained in the source documents from which the data was derived, the source documents need not be retained unless they contain other record information not contained in the electronic repository.


Records relating to compliance with federal affirmative action requirements.

  1. Affirmative Action Plan

    Retention: 2 years after superseded

  2. Report EEO-1

    Employer information reports made by all Denver agencies with more than 100 employees.

    Retention: Copy of most current report must be available [29 CFR 1602.12]

  3. * Report EEO-4

    Records submitted to the Equal Employment Opportunity Commission (EEOC) documenting compliance with EEOC requirements by Denver with 15 or more employees. [Note: Do not confuse this record with EEO-4 Data Record, which is kept at each individual employee’s personnel file, see #90.070*]

    Retention: 3 years [29 CFR 1602.32]

  4. Requests for Reasonable Accommodations

    Requests for reasonable accommodations in hiring or employment.

    Retention: 2 years [29 CFR 1602.31]

  5. * Affirmative Action Records

    Case files relating to discrimination complaints, including the appropriate forms, complaints, legal and investigative documents, exhibits, related communications/documents, withdrawal notices, and decisions or judgments.

    Retention: Resolution of case + 3 years


Individual employment contracts or where contracts or agreements are not in writing, a written memorandum summarizing the terms.

Retention: 3 years after expiration [29 CFR 516.5]


Records pertaining to fringe benefits, insurance coverage and benefit plans for employees.

  1. * Benefit Plans

    Documentation relating to employee health, dental, vision and other insurance plans; including a benefit plan description and/or a summary benefit plan description and amendments. NOTE: Records of deferred compensation plans are maintained by a third-party contractor company.

    Retention: Full period that plan or system is in effect (i.e., as long as anyone is still covered under the plan), plus 1 year after termination of plan [29 CFR 1627.3]

  5. * Enrollment forms

    Records detailing the deferred compensation enrollment; beneficiary designations; selection of benefit plans; records relating to COBRA continuation of health insurance coverage; etc.

    Retention: 7 years


Employee agreements such as conflict of interest, outside employment forms, confidentiality forms, acknowledgement records of relevant Denver Executive Orders; stipulation and agreement such as the Drug & Alcohol tolerance agreement, etc.

Retention: 6 years after leaving position for which the record was filed


Agreements resulting from collective bargaining negotiations and supporting documentation such as general correspondence; records relating to the selection of negotiators, mediators, and arbitrators; negotiation session agendas, notes, recordings, and summaries, etc.

Retention: 3 years after expiration of collective bargaining agreement [29 CFR 516.5]


  1. Pay Plans

    Written plans outlining job titles and pay scales for employees.

    Retention: Permanent

  2. Seniority or Merit Systems

    Retention: For full period plan or system is in effect plus 1 year [29 CFR 1627.3]


Records relating to the planning, coordination, implementation, direction, and evaluation of an employee counseling program. Including reports of interviews, analyses, and similar records relating to the counseling of an employee for work-related, personal, or substance abuse problems.

Retention: 3 years after close of file


Records of periodic checks by Denver agencies that employees have the appropriate valid drivers' licenses.

Retention: Until superseded


  1. Personnel Records under the purview of the Office of Human Resources (OHR) – Denver’s Human Resources Department

    Documentation of an individual employee's work history maintained because of the employer-employee relationship, such as records pertaining to age, current or last-known address, telephone number and social security number; gender and ethnicity; EEO-4 data record, notices of appointment; awards and commendations; disciplinary and personnel actions and supporting documentation, including hiring, evaluation, demotion, promotion, layoff, selection for training or apprenticeships, professional certifications, application and resume, transfer, resignation and termination or involuntary termination; delegation of authority and work assignments; oaths of office; job-related training documentation; performance evaluations; salary documentation; position budget approval; military service; [General Reference: CRS 24-72-202(4.5)]. Note: Medical records are to be retained separately in accordance with federal law. For employee medical records, see 90.110.B, Employee Medical Records in General.

    Retention: 6 years after retirement or separation, provided that records that are updated periodically may be destroyed when superseded and that medical records relating to hazardous material exposure are retained 30 years after separation

  2. Personnel Records housed at individual agency

    Documentation of an individual employee's work history maintained because of the employer-employee relationship, such as records pertaining to age, current or last-known address, telephone number; gender and ethnicity; notices of appointment; tuition reimbursement; classification questionnaires; copies of awards and commendations; verbal reprimand; copies of personnel actions and supporting documentation; settlement agreements copies; delegation of authority and work assignments; emergency notification forms; oaths of office; job-related training documentation; individual safety training records, performance evaluations; salary documentation; position budget approval; military service. [General Reference: CRS 24-72-202(4.5)]. Note: Medical records are to be retained separately in accordance with federal law. For employee medical records, see 90.110.B, Employee Medical Records in General.

    Retention: 6 years after retirement or separation, provided that records that are updated periodically may be destroyed when superseded and that medical records relating to hazardous material exposure are retained 30 years after separation. Prior to records destruction, consult with official record custodian on employee records regarding proper transfer or disposal of departmental employee records upon termination of employment


Records and documentation relating to employment of temporary and seasonal employees, except for payroll and fiscal information.

Retention: 3 years after termination, except payroll and fiscal records

Departmental temporary or seasonal employee records: Consult with record custodian on employee records regarding proper transfer or disposal of departmental employee records upon termination of employment


Records created to control and monitor the issuance of keys, identification cards, passes, or similar instruments of identification and access.

Retention: Until superseded, date of expiration, or date of separation + 2 years, as applicable


Records of verification of employment in response to external requests(i.e., verifications of employment status needed for loans, child support, job applications, etc.).

Retention: 2 years


Reports, studies, aggregated or summarized data,and similar documentation compiled to monitor and demonstrate compliance with the Equal Pay Act.

Retention: 2 years


Records of personnel grievances or complaints filed by employees.

Retention: 6 years after separation of employment.


See also 105.030*, Workers' Compensation.

  1. Commercial Drivers' License Records
    1. Administrative Records

      Records relating to administration of the CDL Program, including copies of expired driver's licenses, DOT physicals, program brochures and flyers, etc.

      Retention: 5 years [49 CFR 382.401(b)(1)(vi)]

    2. Annual Calendar Year Summary

      Retention: 5 years [49 CFR 382.401(b)(1)(vii)]

    3. Calibration Documentation

      Retention: 5 years [49 CFR 382.401(b)(1)(v)]

    4. Collection Process Records

      Retention: 2 years [49 CFR 382.401(b)(2)]

    5. Driving Skills Testing Center Pass/Fail Records

      Retention: 3 years[1 CCR 204-12]

    6. Test Refusal Documentation

      Retention: 5 years [49 CFR 382.401(b)(1)(iii)]

    7. Test Result Records – Alcohol and Controlled substances
      1. Alcohol Test Results
        1. Concentration Greater than 0.02

          Retention: 5 years [49 CFR 382.401(b)(1)(i)]

        2. Concentration Less Than 0.02

          Retention: 1 year [49 CFR 382.401(b)(3)]

      2. Controlled Substance Test Results
        1. Driver Verified Positive Test Results

          Retention: 5 years [49 CFR 382.401(b)(1)(ii)]

        2. Negative and Cancelled Test Results

          Retention: 1 year [49 CFR 382.401(b)(3)]

    8. Training and Education Records – Technicians, Supervisors, Drivers

      Retention: Maintained by employer while individual performs functions which require training and for 2 years after individual ceases to perform those functions [49 CFR 382.401(b)(4)]

  2. * Employee Medical Records in General

    Confidential employee medical records, including: pre-employment physicals; post-employment offer medical examinations and inquiries; job-related medical examinations and inquiries consistent with business necessity; voluntary medical histories obtained as part of an employee health program; pre-employment, post-accident and random drug testing records(not including CDL testing); medical records connected to personnel actions and covered under the requirements of ADA, ADEA, FMLA or OSHA; hazardous materials exposure records, such as records of any personal or environmental monitoring of exposure to hazardous materials, lead and asbestos, chemicals, toxic substances, noise, dust, heat, cold, repetitive motion, blood-borne pathogens, biological agents, bacteria, virus, fungus, radiation, or other dangerous work-related conditions. [General Reference: 29 CFR 1630.14, medical records are not personnel records and must be kept physically separate from employee personnel records.]

    Retention: 6 years after separation from employment, except that employee medical records related to hazardous materials or blood-borne pathogen exposure are to be retained for 30 years after separation from employment and medical records related to workers' compensation cases are to be retained for 10 years after case is closed [29 CFR 1910.1020, 29 CFR 1910.1030]

  3. HIPAA Authorizations for Release of Information

    Employee (patient) authorizations for release of protected health and medical information.

    Retention: 6 years from date of creation of record

  4. * [RESERVED]

90.120 I-9 FORMS

Record of verification of citizenship and eligibility to work in the United States, including verification documentation that establishes identity and eligibility (Immigration and Naturalization Service’s Form I-9, Employment Eligibility Verification Form);applies to all employees hired after November 6, 1986.

Retention: 3 years from date of hire, rehire or 1 year after separation, whichever is later (minimum of 3 years) [8 CFR 274a.2]


  1. *-I). Advertisements of Job Opportunities

    Advertisements and announcements regarding job openings, promotions, training programs or overtime work including job orders submitted to employment agencies.

    Retention: 2 years

  1. *-II). Approval To Fill (ATF) request from agencies

    Records relating to personnel requisitions to fill vacant positions request.

    Retention: 6 years after date of issuance of personnel requisitions.

  2. Applications for Employment and Supporting Documentation

    Applications, resumes and supporting documentation, including polygraph exams, and other replies to job advertisements, including applications for temporary positions and applications from individuals not hired.

    Retention: 2 years from the date of the making of the record or the personnel action involved, whichever is later [29 CFR 1602.31] except for samples of publications, artwork or other products of prior achievement not returned to applicants are to be retained for as long as administratively valuable.

  3. * Background Investigation Files
    1. * Files containing background and/or criminal investigation information such as background checks, CVSA narrative psychological reports, reference checks, etc.

      Retention: 3 years

    2. * Criminal History Records Checks – Airport ID badge holder,Department of Aviation

      Retention: 180 days after an employee has terminated employment with a company

  4. * Aptitude and Skills Test Records

    Records including validation studies, tests, test papers of persons taking tests in relation to aptitude or skills tests required of job applicants or of current personnel to qualify for promotion or transfer.

    Retention: Life of test + 2 years

  5. Fair Credit Reporting Act (FCRA) Records

    Records of reports and investigations by consumer reporting agencies to help employers make hiring or employment-related decisions, including consumer report disclosure to employees, consumer report authorizations from employees, employer certifications to credit reporting agencies, reports from reporting agencies, and summary of rights.

    Retention: Individuals may bring claims under FCRA for 2 years after violation of Act [16 CFR, Appendix to Part 600]

  6. * Job Descriptions and Specifications

    Written descriptions of duties performed qualifications and physical requirements for positions.
    Retention: Permanent

    1. * Supporting Documents

      Documentation concerning the development and analysis of job descriptions and classification systems, including survey, review, and audit reports; classification standards and guidelines; selection criteria, determination of classification appeals, etc.

      Retention: Permanent, except for survey, audit or other reports issued on a regular basis, retain until superseded + 4 years [NOTE: documentation linked to a specific position is to be disposed with job description's retention]

    2. * Classification Files

      Records including audit reports, administrative review files, and classification study history files (“class files”).

      Retention: 3 years

  7. Recruitment and Interviewing Procedures

    Guidelines for recruitment and interviewing processes for hiring of employees.

    Retention: 2 years

  8. * Employee Selection

    Applicant rosters; eligibility test; test ranking sheets; justification statements for violating eligibility or ranking sequence, rejection letter to unsuccessful applicants.

    Retention: 2 years from the creation(or receipt) of the record or the personnel action involved, whichever later.


Records relating to the request to fill a vacant position including but not limited to a justification form, budget authorization, personnel requisitions, etc.

Retention: 1 year


Records containing unused, accumulated leave (if accumulated leave is creditable to an employee when rehired or the leave is used to calculate the length of service).

Retention: Permanent


Records relating to the employee performance evaluation plan but not included the formal review and comments.

Retention: Separation of employment + 6 years

90.134* SIGNATURE CERTIFICATES [Reference: County Schedule 15.240]

Signature certificates of any authorized personnel that are filed with the Career Service Authority

Records Division for authentication and verification of the signature of the official documents.

Retention: 1 year after end of employment

90.140* RESERVED

90.150* PENSION AND RETIREMENT RECORDS See also 90.030.B, Benefit Reports.

  1. Actuarial Reports

    Reports by actuaries concerning the financial soundness of a pension plan.

    Retention: 50 years

  2. * Annual Reports

    Annual reports from a pension system or fund.

    Retention: Permanent

  3. Retirement and Pension Files

    Records containing calculations and supporting documentation regarding retirement eligibility, retirement amounts and other information pertaining to current and future pensions, records of applications for pensions, determinations regarding pension awards and actuarial calculations for the pension.

    Retention: 10 years after benefits are no longer paid or after eligibility of employee or survivors for benefits ceases, whichever is later


  1. Programs that have long-term vital/historical value to Denver

    Records documenting the planning,development, implementation, administration and evaluation of in-house training, career development and organization development programs.

    Retention: Permanent

  2. In-house Programs

    Programs such as the Education Refund Program, etc.

    Retention: 3 years


Investigations of workplace theft or other incidents or activities resulting in economic loss to the employer; copy of statement provided to employee setting forth specific incident or activity under investigation and basis for testing; copy of notice provided to Human Resources professionals identifying persons to be investigated; copies of opinions, reports,charts, written questions, lists, and other records relating to the investigation.

Retention: 6 years after separation of employment.


The State of Colorado requires notification for child support purposes when a new employee is hired as part of the federal parent locater service. Reports are kept for statistical purposes. [General Reference: 42 USC 653]

Retention: 3 years


Studies, statistical reports,surveys, cost analyses and projections, and similar records except those noted elsewhere in this schedule,on any aspect of personnel management.

Retention: 6 years


Retention: Until supersede, or if implemented, 2 years from date of last RIF action under the plan


  1. Safety Training Records

    Manuals, handbooks, and similar documentation of safety training provided to employees.

    Retention: 2 years after superseded or after training is no longer administered, whichever is later

  2. Hazardous Materials Training Records

    Records of training given employees in a hazard communications program showing the date of each training session, subjects covered during the session, rosters of employees who attended, and the names of instructors.

    Retention: 6 years

  3. Blood Borne Pathogen Training Records

    Records of training employees with exposure to blood borne pathogens showing the dates of training sessions, session contents or summaries, names, and job titles of those who received training, and names and qualifications of instructors.

    Retention: 3 years

  4. Others

    Records of a training group or class as a whole including information presented to employees regarding policies and procedures. General and technical aspects of their jobs, and other matters, including class rosters, flyers, and other supporting information.

    Retention: 6 years after separation of employment [Note:If information concerning training or testing (e.g., test scores) is transferred to an Employee Service Record, the document from which the information is taken need only be retained for 2 years]


Reports and claim records for unemployment insurance payments.

Retention: 6 years


Records documenting work performed by individuals without compensation for their services, including applications, records of background investigations, individual recognition, and timesheets.

Retention: 3 years after separation from volunteer service


All tables or schedules (from their last effective date) of the employer which provide the piece rates or other rates used in computing straight-time earnings, wages or salary, or overtime pay computation.

Retention: Permanent


Records of scheduled work for employees, including shift schedules.

Retention: 3 years