Hi Samantha, Assuming there are distinct criteria for hiring the interns (from your other hires), they are likely their own pool of applicants and hires for such purposes as your adverse impact analysis and record keeping requirements. Once interns are brought on as employees, if a company converts them to full time, they are more likely to fit your definition of a transfer or promotion. If there is a break in employment, then they need to apply and be hired like any other rehire. (Though rehires are sometimes not in the same pool for analysis purposes as first time hires.)

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