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Related article: Who is An Applicant? Using the Internet Applicant Rule the Right Way

A core component of compliance with the Office of Federal Contract Compliance Programs (OFCCP) is the Internet Applicant rule. This rule stipulates that Federal contractors and subcontractors must keep data specifically pertaining to recruitment practices centered on Internet hiring and the solicitation of race, gender, and ethnicity of “Internet Applicants.”

Under the Internet Applicant rule, Internet Applicants are defined as those individuals who have been recruited via electronic technologies that involve one or more of the following: 1) electronic mail/email; 2) resume databases; 3) job banks; 4) electronic scanning technology; 5) applicant tracking systems/applicant service providers and 6) applicant screeners.

The OFCCP defines a viable Internet Applicant as follows:

  • Any individual who submits interest in a job via the Internet or any related electronic data technology;
  • The individual is considered for a particular position by the contractor;
  • The individual has the basic qualifications for the position; and
  • The individual does not voluntary remove his or herself for consideration for the open position during the recruiting process.

If a contractor does not use the Internet or related electronic data technologies, they must still abide by record keeping requirements under the guidelines by soliciting demographic information from job seekers.

The record keeping requirement of the Internet Applicant rule serves to provide the OFCCP with data that they can use to ensure contractors are abiding by nondiscrimination laws, and recruitment and hiring practices conform to equal employment hiring standards.

During an audit, the OFCCP will compare the contractor’s Internet Applicant data with labor force data as it relates to women and minorities, and will analyze it to determine whether there are any disparities.

For more information on OFCCP regulations, visit us today at

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Stevens Tate

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