OFCCP

hlylaw · October 2007

Hi, I was wondering what type of protocol or standard procedures some of you have set up for accepting resumes/expressions of interest for OFCCP applicant rules. Do you specifically state applicants for "x" position must apply through the company website, for example? Also, what type of data management techniques have you found helpful?

Thanks!

HR36 · October 2007

In order to define on-line/internet applicants properly, we really just broke down the EEOC's internet applicant definition. So, for us, an "Internet Applicant" is any individual that meets the following four criteria:

• The individual submits an expression of interest in employment through the Internet or related electronic data technologies;

• The contractor considers the individual for employment in a particular position;

• The individual’s expression of interest indicates the individual possesses the basic qualifications for the position;and

• The individual at no point in the contractor’s selection process prior to receiving an offer of employment from the contractor removes himself or herself from further consideration or otherwise indicates that he or she is no longer interested in the position.

We have been rather expansive in interpreting "submits an expression of interest in employment" to include any expression of interest regardless of how it was made or in what form it was made (e.g., submission of a résumé electronically, completion of a form, e-mail requesting an application). However, unsolicited résumés are not considered an expression of interest. Rather, only résumés submitted for a particular position will be considered.

For internal resume databases, we maintain a record of each resume added to the database, a record of the date each resume was added to the database, the position for which each search of the database was made, and corresponding to each search, the substantive search criteria used and the date of the search.

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For external resume databases, we maintain a record of the position for which each search of the database was made, and corresponding to each search, the substantive search criteria used, the date of the search, and the resumes of any job seekers who met the basic qualifications for the particular position who are considered by the contractor. These records must be maintained regardless of whether the individual qualifies as an "Internet Applicant."

OFCCP

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