Understanding OFCCP’s Internet Applicant and Traditional Applicant Recordkeeping Requirements
Understanding OFCCP’s Internet Applicant and
Traditional Applicant Recordkeeping Requirements
Who is an applicant?
An Internet Applicant
A Traditional Applicant
(Non-electronic or non-Internet applicant)
Internet Applicant Traditional Applicant
www.dol.gov/ofccp
• Submits an expression of interest, such as a job application,
resume, or completes screening questions using the
Internet or any electronic technologies such as fax, email,
kiosk or mobile app;
• Is considered for employment by the contractor for a
particular position;
• Meets the basic job qualications based on their
application or resume, and
• Has not withdrawn from consideration before receiving
an oer of employment.
• Expresses interest in a job in writing, or in some limited
instances orally; and
• Has not withdrawn from consideration before receiving
an oer of employment.
Understanding OFCCP’s Internet Applicant and Traditional Applicant Recordkeeping Requirements
How long to keep
applicant records?
An Internet Applicant
Internet Applicant and
A Traditional Applicant
(Non-electronic or non-Internet applicant)
OFCCP's
www.dol.gov/ofccp
Internet Applicant Traditional Applicant
Records must be preserved for 2 years from the time the
record was made or the personnel action was taken
(whichever is later).
Exception: 1 year if the contractor has fewer than 150
employees or less than $150,000 in a federal contract
or subcontract.
Records must be preserved for 2 years from the time
the record was made or the personnel action was taken
(whichever is later).
Exception: 1 year if the contractor has fewer than 150
employees or less than $150,000 in a federal contract
or subcontract.
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Internet Applicant Traditional Applicant
• All expressions of interest that were considered.
• A copy of the basic qualications for each position.
• Copies of job advertisements or postings for each position.
• Copies of applicant screening questions, interview questions,
interview notes, tests, test results, and all other screening
tools used to select applicants from each applicant pool.
• Certain documents resulting from searches of external web
sites (e.g., LinkedIn.com, etc.).
• Demographic data.
• All expressions of interest.
• A copy of the qualications for each position.
• Copies of job advertisements or postings for each
position.
• Copies of applicant screening questions, interview
questions, interview notes, tests, test results, and all
other screening tools used to select applicants from
each applicant pool.
• Demographic data.
What applicant
records to keep?
Understanding OFCCP’s Internet Applicant and Traditional Applicant Recordkeeping Requirements
www.dol.gov/ofccp
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What are some of the key terms
and denitions I should know?
Expression of Interest in Employment
An applicant expresses interest by taking an armative step to obtain a job or a position.
An applicant typically expresses interest by sending a resume, lling out an application
online, posting a resume on an external resume database, or completing pre-screeing
questions in a contractor kiosk or online database.
Considered for Employment
A federal contractor “considers” an applicant for a job or position by reviewing the
application, resume or prole for substantive information, and assessing that information
in light of the qualications associated with the position.
Basic Qualications
These are the qualications the applicant must possess. They are the skills, experience,
and attributes the contractor wants to nd in the candidate hired for the position. The
basic qualications for the position or job must be in writing, objective, noncomparative,
and job related. A contractor must include the basic qualications in the job listing or
advertisement. However, if the contractor does not list or advertise the job, the basic
qualications must be predetermined and reduced to writing or otherwise documented.
Demographic Data
This is information about the person’s race, sex, disability, and veteran status. Voluntary
self-identication is the preferred method for collecting demographic data. In situations
where the person does not self-identify, observer information may be used. However, if
a contractor is unsure, the contractor should not guess.
Understanding OFCCP’s Internet Applicant and Traditional Applicant Recordkeeping Requirements
Resources
Where can I
learn more?
Who can I
contact for
assistance?
Find more information and tools at
www.dol.gov/ofccp:
• Frequently Asked Questions
• Sample Armative Action Program
• Workplace Posters
Additional assistance is available:
• Call OFCCP’s Toll-Free Help Line 1-800-397-6251 (TTY 1-877-889-5627)
• Online at www.dol.gov/ofccp
www.dol.gov/ofccp
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Oce of Federal Contract Compliance Programs
UNITED STATES DEPARTMENT OF LABOR
200 Constitution Avenue, NW | Room C-3325 | Washington, D.C. 20210
phone 1-800-397-6251 | TTY 1–877–889–5627 | fax 202-693-1304
August 2019
Please note that this Quick Reference Guide provides general information. It is not intended to substitute for the actual laws and regulations
governing OFCCP and its enforcement program.