OFCCP Staffing Compliance
OFCCP Approved Process & Documentation provided with our Job Posts, Resume Search, & Professional Search Services
OFCCP
Overview
On March 4, 2004, the OFCCP (Office of Federal Contract Compliance Programs), issued the Final Rule on job applicant regulations for employment candidates who apply for a job over the internet and related data technologies and the required electronic tracking and record-keeping.
Many employers have incorrectly determined that because they are not a Federal Contractor they do not need to adhere to OFCCP requirements. Subcontractors also need to meet these new requirements, which includes any employer with 50 or more employees and receives more that $50,000 from a federal contractor in performance of a federal contract.
The OFCCP requires specific records be kept for any subsequent OFCCP audit, to verify that the employer's hiring practices did not have a disparate impact based on race, gender, or ethnicity. All Internet Applicants who meet the employer's basic job requirements are subject to required record keeping. For resume database searches, records must be kept of the position, the search criteria, the date of the search, and all resumes that meet the basic qualifications. The employer is required to solicit & keep records regarding gender, race, and ethnicity of each Internet Applicant. Records must be kept for up to 2 years in the advent of an OFCCP audit.
Internet Applicants
The OFCCP has specific rules on who is considered an Internet Applicant subject to the required record keeping. A Candidate is an Internet Applicant if all 4 of the following tests are met:
- The person expresses interest in employment through the Internet.
- The person is being considered for a specific position.
- The person has met the Basic Requirements for the specific position.
- The person does not withdraw from consideration for the position.
Applicant Logs
The OFCCP has recently begun asking contractors to keep detailed Appliant Logs to be presented at a desk review or an audit. Log information should include
- Candidate Name
- Date of application
- Job & location applied for
- Race
- Sex
- Disposition
If a candidate meets the basic qualifications and is an Internet Applicant, then this log must be kept for each candidate and must track and record the disposition of the candidate for each step of the selection process until the candidate is hired, rejected, or voluntarily withdraws from consideration.
Our Record Keeping & Tracking Services are included in all our Job Post, Resume Sourcing, & Professional Search services