Best Practices for Taking Compliant Interview Notes

As a Federal Contractor the University of Pennsylvania (UPenn) is subject to regulations of the Office of Federal Contract Compliance Programs (OFCCP) and required to adequately document and retain all records related to faculty searches. As such departments must retain interview notes of search committee members and search committees as part of the official record.

All documentation related to searches is discoverable, including interview notes, and may be reviewed in the case of an audit by the OFCCP or the UPenn Office of Audit, Compliance, and Privacy, or in cases of an employment complaint.

Search documentation should be clear enough and detailed enough that it can help departments, auditors, and the University understand the preferred candidate’s skills and qualifications and how those skills and qualifications compared to other candidates under consideration. Audits and inquiries can take place years after a search has been completed, so it is critical that this information and the logic behind decisions is accessible in the documentation. Interview notes play an important part in achieving this goal by helping capture key information that surfaces in an interview.                             

  • Record notes on a dedicated document. Interview notes and observations should not be recorded on a candidate’s application or resume.
  • Notes should contain the name of the candidate, name of note taker, and date.
  • Record key information, keep notes brief.
  • Notes should be factual and objective.
  • Focus notes on information that is directly relevant to the position description.
  • Avoid inquiries based on an applicant’s protected class. Examples can be found on the University of Pennsylvania’s Avoiding Bias in the Hiring Process webpage. This resource is accessed via Pennkey. If you do not have a Pennkey, your department Faculty Coordinator can help you access the information. 
  • In cases where an interviewed candidate happens to volunteer information regarding their protected characteristics during the search or interview, the information should neither be documented nor shared with other interviewers or search committee members.
  • Avoid observations regarding a candidate’s physical appearance or characteristics.
  • Avoid conclusions and/or statements that infer or are based on a protected characteristic e.g., “pregnant,” “stuck in the past,” “may not be able to perform work,” etc.
  • Departments can build consistency in their process by developing a template for taking notes.

Related Resources

Additional resources and best practices for managing faculty searches can be found throughout OAA’s Search and Recruitment webpages and the University of Pennsylvania’s Office of the Vice Provost’s Recruiting Excellent and Diverse Faculty webpage.