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Related article: Why Do You Need to Be OFCCP Compliant? Find Out.

The Office of Federal Contract Compliance Programs (OFCCP) is responsible for ensuring compliance with Executive Order 11246, and all regulations pertaining to making job vacancies available to qualified applicants representing minorities, veterans, women and persons with disabilities. If you are a federal contractor who needs to comply with OFCCP regulations, one area you should be aware of is the record-keeping requirements regarding Internet Applicants. Below is information to help you understand and meet this compliance criteria.

OFCCP’s definition of an “Internet Applicant”

Job seekers who meet all four requirements are considered “Internet Applicants.”

  • 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.


Electronic data technologies include:

  • Email
  • Resume databases
  • Job banks
  • Electronic scanning technology
  • Applicant tracking systems/applicant service providers
  • Applicant screeners


Record-keeping Responsibilities of Federal Contractors

As part your efforts to comply with OFCCP’s recordkeeping regulations for Internet Applicants, the following information must be maintained and provided upon request:

  • Background information, including position, search requirements, and job advertisements and postings.
  • The position, search date and criteria must be recorded.
  • All electronic expressions of interest from electronic job seekers must be retained, including all applications and resumes, even if the individual fails to meet the basic qualifications of the job opening.
  • Race, ethnicity and gender data which has been solicited from Internet Applicants.
  • Other records including paper applications or resumes, any tests and test results, and any interview notes should also be maintained.


For more information on OFCCP compliance, visit us today at

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