Employer Compliance to Avoid I-9 Penalties: Retention and Purging I-9s, Part 10 of 12
Where to Keep I-9 RecordsKeep all I-9 forms and records separate from other personnel records.
Rationale: keeping the I-9 form in the personnel file of each employee might expose those files to government examiners when an audit is performed by the government, to the detriment of the employee's privacy. It also provides information to the employee's supervisor regarding citizenship status and age that should be irrelevant to the person's employment. The I-9 file for a particular job site may be kept at that job site or may be sent to the employer's headquarters. Which approach is considered best must be determined for each employer.
Purging (Shredding or Deleting Electronic Versions) of I-9sRationale to purge: Avoid penalties and sanctions on old I-9s.
Purge the LATER OF
(1) 3 Years After the Date of Hire or
(2) 1 Year After Date of Termination.
Typically this means for the full period of employment, plus 1 year.
Recruiters/referrers: purge 3 years after referral date.