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Applicants/Union/Seniority question for EEO/AAP

Heather K. - Sep 23, 2016
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We are a federal contractor and also are union. Due to the nature of our business we often lay off people for short periods of time and then call them back from the union based on seniority when we need them back. For Affirmative Action Plan purposes, are we supposed to track every person called back from the union as an “applicant” each time they are rehired? And when we rehire someone by requesting them back from the union, are they considered an external or internal applicant (if they are supposed to be tracked as an applicant each time they are rehired)? Are we required to post the job on the state job board when we call people back even though our union contract specifies we must call back people with seniority from the union when we have the position available again? Are there any resources available for ofccp compliance specifically for union employers?

1 Answer

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Ahmed Younies

President and CEO, HR Unlimited, Inc.

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Bill Osterndorf

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Carla Irwin, Esq.

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Craig Leen

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Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Lisa Kaiser, Esq.

Managing Partner, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

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William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

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