To keep officer training records ready for an audit or a client request, file each officer’s certificates and continuing education proof in their personnel file as soon as the school issues them, track who is still in training from one live view, and know which records the school keeps on its end. The Texas Administrative Code puts continuing education proof on the employer, sets a seven-day deadline for schools to issue original certificates, and requires schools to keep training records for 24 months. Build your filing around those three points and most requests become a five-minute task.
The trouble usually starts when records live in three places: an officer’s email inbox, a folder on someone’s desk and a spreadsheet nobody has updated since spring. Here is how to pull that into one system.
Who is responsible for keeping training proof?
For continuing education, the employer is. 37 TAC §35.161(a) says proof of the required continuing education must be maintained by the employer in the employee’s personnel file. The same subsection says a renewal application may not be submitted until the required hours are earned, so the personnel file is where that proof needs to be before anyone files.
That makes the personnel file, not the officer’s phone, the record that counts. If an officer leaves and takes their email with them, the proof has to still be in your file.
What does the school keep, and for how long?
The approved school has its own obligations, and they are useful to know when you are missing a document:
- Certificates are issued within seven days. Under 37 TAC §35.147(a)(1), the approved school issues the original certificate within seven days after the student qualifies.
- Training records are retained for 24 months. Under §35.147(a)(4), schools retain training records for 24 months.
Two practical takeaways. First, if a certificate has not shown up a week or so after an officer qualified, follow up then, not three months later when a client asks for it. Second, the school’s retention period is finite. Your personnel file is the long-term copy, so get the document into it while it is easy to get.
What should be in each officer’s training file?
A simple, consistent checklist beats a clever system. For each officer, keep:
- The certificate for every course completed, such as Level 2, Level 3, Level 4 and OC Pepper Spray, with the completion date visible.
- Continuing education proof for each renewal cycle, for commissioned officers and personal protection officers.
- The officer’s license type and expiration date on a cover sheet, so anyone opening the file can see where they stand.
- The school’s name on each record, so you know who to contact if a copy is ever needed.
Use the same order in every file. An auditor or a client compliance contact will move faster through ten identical files than through ten folders organized ten different ways, and so will your own staff.
A note on unarmed officers
Noncommissioned security officers are exempt from continuing education under 37 TAC §35.161(b), so their files will not have renewal hours to track. Their course certificates still belong in the file.
How do you track officers who are still in training?
Finished training goes in the personnel file. Training in progress is a different problem, and it is the one clients ask about most: “Will your new officers be ready for our site by the start date?”
When you book through our group training program, your company gets a manager login. One screen shows every officer on your roster and whether they have started, finished, or not signed in yet. It is scoped to your company only, so you see your people and nobody else’s. When a client asks for a status update, you can answer from that screen instead of texting each officer.
It also tells you who needs a nudge. An officer who has not signed in a week after the roster went out is the one to call, before the in-person date is booked around them.
How does group booking make the paperwork easier?
Records get messy when every officer trains on a different schedule with a different school and pays with a different card. Group training removes most of that variation:
- One invoice covers every officer, paid in advance, so your accounting has one document instead of a stack of reimbursement receipts.
- One roster creates every officer’s account and login by email automatically, already enrolled, so you know exactly who is in the program from day one.
- One school for the whole group means one contact for every certificate.
- One in-person session for the group, at your facility or at East Texas Rifle and Pistol Club in Longview, means the group qualifies on the same day, so their records can be filed together.
The minimum group is five officers. If you are training fewer, they can enroll individually, and the same filing checklist applies.
What should you do this week?
Pick three officer files at random and check them against the checklist above. If any certificate or continuing education record is missing, request it now while the school still has it on hand. Then put a recurring reminder on the calendar to file new certificates as they arrive, so the gap does not reopen.
Recordkeeping FAQ
How soon after the class will we have the certificate?
Under 37 TAC §35.147(a)(1), the approved school issues the original certificate within seven days after the student qualifies.
Can we rely on the school to keep records for us?
Not long term. 37 TAC §35.147(a)(4) requires schools to keep training records for 24 months, while §35.161(a) puts continuing education proof in your personnel file. Keep your own copy of everything.
Can the manager login show other companies’ officers?
No. The manager login is scoped to your company only and shows your roster’s progress. For other questions, see our FAQs.


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