Who is an applicant and how do you track EEO data on them?

HRGddss

If you could please define who are your applicants and how you track their EEO data, I would appreciate it. I am pretty sure our process is wrong and am seeking any guidance possible. Reference to fed docs also welcome.

Thank you for any help! I'm drowning in resumes!!

rad

Hr.com is having an on-line seminar about exactly this. Here is the seminar link site.

[url]http://www.hr.com/Events/HRSeminarsDesc.cfm?eventID=33[/url]

Don D

[font size="1" color="#FF0000"]LAST EDITED ON 04-20-04 AT 08:18AM (CST)[/font][br][br]If you are a government contractor subject to Executive Order 11246, and you're drowning in resumes, all of those resumes represent applicants by definition, simply because you accepted them, some would say. If you do not accept applications or resumes except when you are in an announced recruitment mode, then none of those that come in otherwise are considered applicants nor are the resumes, unless you retain them and utilize them in some manner. We do not track resumes that come in, only those that may result in an application and interview.

Our application has attachments requesting voluntary disclosure of demographic data for affirmative action logging. Whether or not you're required to have an AAP, you'd be wise to restrict and limit your application process and tightly define your resume receipt policy.

What is it about your definitions and processes that you feel may be 'wrong'?

HRGddss

We are a fed contractor but I have a jillion resumes and no eeo data. So I'm to guess about their ethnicitiy, etc.

First, the jillion resumes is a problem in a manual tracking environment. Secondly, there is nothing I see defensible about a system in which I am guessing all of the eeo factors based on location/name/random things they might have on the resume.

Don D

There is no way to guess at the information and I've never heard anyone suggest we do that. We only get that data from the self disclosure portion of the application.

Kymm

Ok... so is there a problem with this "scenario".. we do not have any current job openings, but we get some resumes in, so we just "file them away" for possible future use. We do NOT track them at that point. Now... a month later we pull a couple out, call them and have them come in for an interview AND complete an application. AT THAT TIME, we start "tracking" them. Does that sound ok?

dbutton111

We only track EEO data on those resumes we consider actual applicants - came in or completed an application for employment.

Gillian3

Start by defining an applicant as someone who is qualified for your jobs, then start using specific application or resume acceptance periods tied in to recruiting activity. Put unsolicited resume's for individuals who aren't qualified for your jobs into the round file.

Don D

>Start by defining an applicant as someone who is
>qualified for your jobs, then start using
>specific application or resume acceptance
>periods tied in to recruiting activity. Put
>unsolicited resume's for individuals who aren't
>qualified for your jobs into the round file.


I respectfully disagree Gillian3. If I were to define as an applicant those individuals who are qualified for my jobs, what would I consider all those whom I recruited and interviewed who were determined to not qualify for my jobs? The government certainly considers them applicants and will expect me to do the same when they come a knockin'.

HRGddss

> >Start by defining an applicant as someone who is
>>qualified for your jobs, then start using
>>specific application or resume acceptance
>>periods tied in to recruiting activity. Put
>>unsolicited resume's for individuals who aren't
>>qualified for your jobs into the round file.
>
>
>I respectfully disagree Gillian3. If I were to
>define as an applicant those individuals who are
>qualified for my jobs, what would I consider all
>those whom I recruited and interviewed who were
>determined to not qualify for my jobs? The
>government certainly considers them applicants
>and will expect me to do the same when they come
>a knockin'.

This is the conflicting definition problem. Yuck. Don, what do you do?

Gillian3

The bottom line is that your definition of someone who is qualified and the definition of someone from the OFCCP will be different. They will assume "qualified" when you know they are not, therefore, the goal is to minimize the number of these individuals so that they are not part of your data base, waiting to be reviewed by the the auditor. They are minimized by being screened out in the process. The gray area are those who could be seen as "qualified" with a little stretch - you require two years experience, the person has one and a half for example - I would include that person. It all boils down to how aggressive you want to be - if you are too aggressive and the auditor says so, you can relax the standards a bit.

Don D

I hate to belabor the point, but, when the investigator asks me (as they did last October) how many people were interviewed for a particular job, they could care less at that point which were determined qualified. They are asking me how many were in the applicant pool so that they can run an analysis of the demographics of my pool as compared to the demographics of the selected individual. I suggest we CANNOT define applicant as a person who is qualified since at least some of your applicants will be determined not qualified and if you interviewed them, their inclusion in your applicant pool is required by law, if you're a government contractor under 11246. x:-)

Gillian3

Correct, if we interviewed them they are an applicant. No point in belaboring a grey area either, but why interview an unqualified applicant.

HRGddss

But how do you define your EEO flow using only data on a resume? I have yet to see one that said they were a black, male, vietnam-era vet with a disability.

System

Don, didn't you tell us once that you discard all unsolicited applications? I have been told to keep all apps, even the unsolicited ones, for 12 months. Is that true? We have never once gone through these old applications and called anyone if we needed to hire someone. I'd like to burn them myself.

DeidreFR5

[font size="1" color="#FF0000"]LAST EDITED ON 04-20-04 AT 11:19AM (CST)[/font][br][br]We state on our open positions listing and on our website that only completion of an employment application constitutes a job application; receipt of an resume does not constitute application for an open position; we only accept applications for current open positions are listed on our website. We had a problem with unsolicited resumes in the past and our AAP company advised us to define our "application", also, if we did not know the EEO information, they had to default to white male.

Don D

HRGddss: You are not required by law to track the demographics of resumes that do not develop to the point of application and interview.

Linda: We don't have any 'unsolicited applications'. We do have 'unsolicited resumes', which are discarded. We only hand an application to someone who responds to an open recruitment period and is basically there at our invitation or has walked in in response to an ad or referred by an agency or headhunter at our request.

Gillian: Methinks you've been in academia too long. In my world, it often takes an interview with one or more of our personnel to clearly determine who is or might not be qualified. Often that is not readily apparent from a piece of paper. If that were the case, we could simply review paper, push it all into a sorting machine and have it line everything up chronologically and hire from the oldest paper forward. I have found this to be true in state government, the transportation industry and several manufacturing firms where I have worked.

System

Thanks, Don. Every day we have guys walk in uninvited and fill out an application. We're in construction, and when word spreads that we're on a site, in flood guys looking for a better job, higher wages, etc. I have half a file drawer full of unsolicited apps. So I can toss them?

Don D

I would not recommend tossing them since you did take them during a prior policy and you might be called upon to produce them. I'd bundle them and record the most recent date on the bundle and toss them one year after that date. I'd also not allow people to walk in and fill them out anymore unless you need that traffic to populate your jobs. Put a 'no applications being taken' sign up and enforce it. Once you open the gate to one application, however, you'll need to do it for all on that day. Don't get caught selectively allowing people to complete applications. On those days when you do need to recruit, turn the sign over to the side that reads 'applications being taken', or take them on Wednesday only, whatever. Don't let the paper bury you.

System

[font size="1" color="#FF0000"]LAST EDITED ON 04-20-04 AT 12:39PM (CST)[/font][br][br]Oops! Never mind...

Gillian3

Nah, my opinions don't come from academia, a brief four years out of many, but from interpreting OFCCP auditors audit AAP's in manufacturing companies. Guess it goes to show that OFCCP auditors interpret their regulations differently, just like all the other enforcement people that are out there.

Sunny

I got burned on this one - when I started working at my present company their policy was to leave applications in the (unattended) lobby and let folks fill them out at will. After our OFCCP audit, I removed these and now I define an applicant as an individual who has filled out an application and been interviewed. I "take applications" at specific times and interview each applicant who then goes on my flow chart for tracking.

When I fill other types of jobs - through advertisements on on-line postings I do the same- an applicant is someone who fills out an application and has an interview.

You really can't guess at someones ethnicity - and these days you can't even really tell gender by names. After all, my husband's name is Lynn and mine is Sunny.

System

Our practice is to allow anyone who requests an application to complete one, whether we need help or not. These are usually for our field construction positions. I was instructed to keep them for a year. I'm wondering now, since management won't change this practice, if I should be "categorizing" these folks for tracking purposes. I have also been instructed to greet and talk briefly with all Hispanic applicants (my supervisor talks to the English speaking applicants) and let them know whether we are hiring. Any advice?

Don D

Confuscious say, "Always follow advice of supervisor. To do otherwise, lead to short path out front gate."

Patty

We are not required to keep this data, but I do anyway. My previous job was with a very large corporation that did get audited and so just to be safe I began tracking applicants when I took this job 3 years ago. I consider anyone I interview face-to-face an applicant. I stopped taking applications when I don't have open positions. This way you can make an "educated" guess on ethnicity. Data I track is date of interview, name gender, race, position applied for, source of applicant (newpaper, referral, walk-in) who interviewed the applicant other than me and the results of the interview. I have posted jobs on the workforce website, and still only consider those I interview as applicants. I keep all of the other resumes I receive in response to the posting in a file for that month for 1 year. I have been known to go back into that file and contact someone I didn't initially.

Don D

Are you working for a government contractor, and, if not, for what purpose are you doing all this tracking?

Don D

Kim: Regarding your post number 25, the OFCCP would cite this as problematic and you'd be in a bind to explain the practice. Their assumption would be that you are receiving and not tracking resumes, then pulling from that stack those you want to call in, thus culling those who you might want to avoid contact with. Similar to an EEOC opinion, they would find that your practice is discriminatory on its face, although that may not be your intent at all. You either do or you do not accept and act on resumes. They won't find it acceptable for you to shove some into a file and pull them later. No matter what your explanation might be, the Feds will not find it proper in this context.

Kymm

Thanks Don... guess I'm just confused and trying to figure out the best way to do this "applicant tracking". I think I just didn't follow you through your entire "process"..... you said that you only tracked resumes that became part of the interview process, right? But you were also saying that you ONLY accept resumes at "certain times" (when you have openings, I presume). ??

Don D

Here's the deal, short and sweet. When we have an opening, we accept applications. Only then do we accept applications. Any resumes that come in at other times are not retained. When we announce, post, advertise an opening we both accept applications and resumes for that opening. If we receive a resume and the person is not called in for interview, then that resume is not logged because it is not yet an applicant. We will call in for interview those who submit resumes and are apparently qualified and then we interview and log their demographics.

It never fails that when we advertise an opening we get resumes from a hundred people who are just sending one because they saw our address in the ad. Most are not remotely qualified. We have no interest in those and do not act on them, thus do not list their demographics in our AAP process.

You may on occasion miss a good resume you might have wished you'd kept to pull it later. That little bit of consternation is far outweighed by all the pain you create by logging/tracking all of the resumes you receive throughout the year and all the applications you may allow people to fill out when you are not hiring. Tighten it up substantially and you'll breath much easier.

I lied when I said "short and sweet". x:-)

mushroomHR

We are a federal contractor and are required to have an affirmative action plan as well as do applicant tracking. We have been told by the consultant that helps us with our AAP that we must track all resumes that come in in response to an ad that we have placed. Of course we don't know if they are male/female/black/white, etc. but we are supposed to guess to the best of our ability as to their race, sex, and any veteran status. We guess based on a name, and address which sounds silly but that is what we were told to do. The only other suggestion for gathering this data was to prepare post cards to mail to those who submit resumes and ask them to self identify and return the post card. That would be a real nightmare. We have decided to forego that idea.

However, if you are a federal contractor I do believe you have to track these resumes to the best of your ability. Only consider those that are sent in as a result of an ad you have placed. If you have no positions available and get walk in applications, I wouldn't count them. I also agree that you should limit your walk-in applicants.

Sunny

You have hit the major bone of contention between contractors and the OFCCP. The definition of an applicant is an ongoing argument and Don's position is the position of many contractors now. This is because it is a logistical nightmare to try to track all the meaningless resumes that come in bearing no resemblance to the position advertised. By the way, I was told, pursuant to an OFCCP audit, that we had to send those postcards. I duly put one in my AAP. I have noticed that some on-line applications have a section (voluntary) of course, that requests EEO data. Maybe that will be the wave of the future. In the meantime, your way is the way preferred by the OFCCP but it isn't actually set in stone as far as I know.