You ask job applicants to self-identify as protected veterans. Good. That data feeds your VETS-4212 report and your hiring benchmark. But the moment you collect it, you own a problem most HR teams never think about. Where does that data live? Who can see it? How long do you keep it?

Get this wrong and you are not just sloppy. You are out of step with federal rules. The same rules that ask you to collect veteran status also tell you how to lock it down. The data has to stay confidential. It has to live apart from the application. And only a short list of people can touch it.

This article is the data-handling lens. It is not about the invitation form itself. We have a separate piece on the protected veteran self-identification form and when to send it. Read that one for the pre-offer and post-offer mechanics. This one covers what happens after the data comes in. Storage. Access. Retention. The stuff that gets you flagged in an audit.

Why is veteran self-ID data treated like a medical record?

Here is the part that surprises people. The rules treat veteran self-identification data almost like a medical file. That is on purpose.

The veteran self-ID invitation often sits next to a disability self-ID question. Both ask for protected, personal facts. Both can reveal things a hiring team should never weigh when picking who to hire. So the law builds a wall around the data. It has to be collected on separate forms. It has to be kept in a separate file. And it gets treated as a confidential record.

The regulation behind this is 41 CFR 60-300.42. It requires contractors to keep all veteran self-identification data confidential. The separate-file rule comes from 41 CFR 60-300.23. That section governs medical and disability data and applies here by cross-reference. The exact words are: collected and maintained on separate forms, kept in separate medical files, and treated as a confidential medical record. That phrase matters. Confidential. Separate. Not loose in the applicant file.

Think about why. Say a hiring manager opens an application and sees "protected veteran" on page one. That fact can color the decision. Maybe it helps. Maybe it hurts. Either way, the data leaked into a place it should not be. The wall exists so the hiring call stays clean and the data stays protected.

How should you store protected veteran data?

Storage is where most teams trip. The rule is simple to state and easy to break. Keep the self-ID data apart from the application and apart from the regular personnel file.

That means the veteran status answer does not ride along in the resume, the application form, or the interview notes. It lives in its own place. If you use paper, that is a separate locked file. If you use a system, that is a separate field or table with its own access controls.

What "separate" looks like in practice

Most midsize employers run an applicant tracking system. Your ATS racks and stacks candidates. It does not reject them, it sorts and scores them. The self-ID data should never appear in the fields a recruiter or hiring manager sees while sorting.

Good systems wall this off by design. The self-ID answers feed a back-end compliance module. The front-end hiring screens never show them. If your tool cannot do that, you have a storage problem to fix before you collect another form.

Digital storage cautions

Paper files were easier in one way. A locked drawer is a clear line. Digital data leaks in quiet ways. A spreadsheet someone exports. A report that pulls more columns than it should. A shared drive with loose permissions.

Lock the digital side the same way you would lock the drawer. Limit who can query the field. Limit who can export it. Keep an audit trail of who pulled what. If a report only needs counts, do not let it pull names attached to veteran status.

Picture a real slip. A recruiter at a 200-person firm builds a candidate report and adds every available column "to be thorough." Veteran status rides along. The report lands in a hiring manager's inbox. A protected fact sat in front of the decision-maker. Nobody meant for it to. No bad intent. Just a loose export and a default that pulled too much.

That is the kind of gap an auditor finds and a small fix prevents. Set your reports to pull only what each one needs. Build the veteran status field so it cannot leave the compliance module by accident. The wall holds when the system holds it, not when people remember to be careful.

Who has a need-to-know for veteran status data?

This is the question that protects you in an audit. The default is that almost nobody on the hiring side gets to see individual veteran status. Access is limited to people who genuinely need it for a defined reason.

The regulation lists a short set of exceptions. Outside of these, the data stays locked. Here is the list straight from 41 CFR 60-300.23.

Notice who is not on that list. The recruiter sorting resumes. The hiring manager picking interviews. The team lead who wants to "support our veterans." None of them get individual self-ID data as part of the hiring call. Good intent does not create a need-to-know.

The cleanest way to handle access is to name one role. Name one compliance lead or HR person. They own the data, run the reports, and answer to OFCCP if asked. Everyone else stays out by default.

How does this data feed VETS-4212 and your benchmark?

Here is the part that confuses people. You collect individual answers, but you report in aggregate. The wall stays up even when the data does its job.

Your VETS-4212 report asks for counts, not names. How many protected veterans you hired. How many you employ. The report rolls up the individual answers into numbers. No single veteran is named. The filing season runs August 1 through September 30 each year, and the report goes to the Department of Labor.

The hiring benchmark works the same way. You compare your aggregate veteran hiring against a national rate. The current benchmark is 5.1%, effective July 30, 2025. Always confirm the live figure on the OFCCP page at dol.gov before you use it, because it updates. Our piece on the OFCCP veteran hiring benchmark walks through the tracking math if you own that work.

So the data is doing real work. It proves your veteran hiring numbers. It feeds the benchmark check. But it does all of that as totals. The individual fact stays in its locked file, used only to build the affirmative action program. That is the whole reason you are allowed to collect it.

How long do you keep protected veteran records?

Retention is the other half of the data problem. You cannot keep this data forever, and you cannot toss it the day after you file. The rule sets a floor.

Under 41 CFR 60-300.80, the general rule is two years. Keep personnel and employment records for two years. The clock starts from the date you made the record or took the action, whichever is later.

Smaller employers get a shorter floor. If you have fewer than 150 employees, or no government contract of at least $150,000, the minimum drops to one year. Same trigger, just a shorter clock.

A few records run longer. Some data tied to your benchmark and outreach work has to be kept for three years. When you terminate someone, that person's records clock runs from the termination date, not the hire date. Read the regulation for the exact list, because the categories matter.

The takeaway is that retention is a floor, not a guess. Set a calendar. Know which records sit in which bucket. An auditor who asks for two years of data and gets a shrug will dig deeper.

What does an OFCCP audit actually check on data handling?

If OFCCP comes knocking, the data process gets a close look. They are not just checking that you collected self-ID. They check how you handled it after.

Expect questions on four fronts. These are the same four every contractor should be able to answer cold.

If you can answer those four clean, your data process is in good shape. If any one of them gets a "we think so," fix it now. The fix is cheap before an audit and expensive during one.

This whole topic sits inside a bigger picture. If you want the full obligations view, read our VEVRAA compliance guide for federal contractors. It covers who is covered, the affirmative action plan, and how the pieces connect. And if you are not sure which veterans even count, our breakdown of what makes someone a protected veteran defines the four categories.

Where do you find the veteran talent worth tracking?

Clean data handling matters more when you actually have veterans in your pipeline. A locked, well-run self-ID process is useless if no veterans apply in the first place.

That is where Best Military Resume fits. We run a growing pool of veteran candidates for employers who want to hire from the military community. More than 1,000 new veteran profiles are added every month, and our platform has built over 60,000 resumes. The supply is fresh and it keeps growing.

So you get two things at once. A steady stream of veteran applicants to fill your roles. And a real reason to run the self-ID and reporting process right. If you want access to the pool, reach out about hiring veterans through BMR.

Handle the data right. Keep it separate. Limit who sees it. Report in totals. Hold it for the full window. Do that, and the part of veteran hiring that scares HR teams becomes routine. The hard part was never the paperwork. It was knowing the rules. Now you do.