OFCCP’s four-part definition of “Internet Applicant.”

Does an applicant have to meet all 4 parts of this definition in order to meet the definition of "Internet Applicant?"  Thank you.


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  • Good afternoon, please see the information below from the Society for Human Resource Management (SHRM) website. The bold, italicized section may answer the question for you:

     POSTED on SHRM on 12/4/2012

    "Certain criteria in addition to electronic submission must be met, according to the Office of Federal Contract Compliance Programs (OFCCP) in its final rule.

    Effective Feb. 6, 2006, the OFCCP's final rule affects covered federal government contractors. The objective of OFCCP's recent rule is to create flexibility for contractors to come up with a system that will ease recordkeeping burdens and to assist in evaluating whether federal contractors are recruiting a diverse pool of qualified applicants and hiring new employees on a nondiscriminatory basis.

    A candidate meets the definition of an Internet applicant if the following criteria are met:

    • The individual submits an expression of interest in employment through the Internet or related electronic data technologies.
    • The contractor considers the individual for a particular position.
    • The individual's expression of interest indicates the individual possesses the basic objective qualifications for the position.
    • The individual at no point in the contractor's selection process prior to receiving an offer of employment removes him or herself from consideration or otherwise indicates that he or she is no longer interested in the position.

    If the above criteria have been met, the contractor must retain all application or resume responses through the Internet or related electronic data technologies for two years. To minimize the potential volume of records, the OFCCP does not require contractors to retain records of individuals never considered for a position.

    And under OFCCP's final rule, contractors do not have to consider job posting responses that are not submitted in accordance with the contractor's standard procedures. Critically important for contactors to remember is that if the contractor considers expressions of interest through both the Internet and the traditional means the Internet applicant regulations apply to both types of submissions.

    If the contractor does not accept electronic submissions for a position, the Internet definition of an applicant does not apply."


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