Best Practices for Purging Forms I-9

What should employers do with an employee’s Form I-9 after the employee leaves the company? It’s a best practice that employers purge the I-9, according to the form’s retention requirements. This step is often neglected in an organization’s Form I-9 maintenance process – and it increases risk. Listen to our podcast to find out why. It’s no easy task to stay on top of purging I-9s. It can be hard for HR staff to keep track of the retention timeline for each Form I-9 in the company, especially with how often employees may come and go.

When to Purge a Form I-9?

Employers must calculate when an I-9 should be purged from their files. They determine the dates for:

• three years after the employee’s initial date of hire
• one year after the date employment is terminated

Then, the employer should purge the I-9 on whichever date is later.

Don’t Delay and Put Your Company at Risk

These best practices help ensure your organization manages this step correctly.

• If you maintain paper Form I-9s, purge the form and all supporting documents.
• If you maintain electronic Form I-9s, purge the image of the I-9, any electronic copies of supporting documents,and all audit records associated with the form.
• Keep Form I-9s separate from personnel files.
• Avoid purging I-9s yearly or quarterly. This step should be an ongoing process.
• There could be the rare occasion when your legal department requests that you retain copies of Forms I-9 that may be subject to further or ongoing litigation.
• Consider an electronic solution like I-9 management from Equifax. It provides a comprehensive repository of all of your I-9s. When combined with the Work Number, it can calculate retention requirements and automatically purge documents.

For more information on this topic, listen to the Workforce Wise™podcast. While you’re there, check out our other episodes -- and don’t forget to subscribe if you like what you hear.