The obligation requiring federal contractors to record resume database searches is stated under OFCCP’s Internet Applicant Recordkeeping Rule. In 41 C.F.R. § 60-1.3 OFCCP defines who is an Internet Applicant and in 41 C.F.R. 60-1.12 it sets forth the record retention requirements for federal contractors. Federal contractors must save records when they search a resume database, whether it is an internal or external database. For internal resume database searches, you will need to keep a record of the following: • A record of each resume added to the database • A record of the date each resume was added to the database • A record of the position for which each search of the database was made • The date of the search for each search conducted • The substantive search criteria for each search conducted – such as experience, degree, location, industry, and key words used When searching for candidates on an external resume database, you will need to maintain the following records: • A record of the position for which each search of the database was made • The date of the search for each search conducted • The substantive search criteria for each search conducted – such as experience, degree, location, industry, and key words used • The resumes of job seekers who met the basic qualifications for the particular position who you considered for the position. You are not required to maintain the resumes of individuals if you did not consider them for the position. You are also not required to maintain a record of searches that do not produce candidates that meet the basic qualifications. • While the OFCCP does not specifically require this, it would be beneficial for you to document any data management techniques you used. For example, your company may have a policy of only reviewing the first 50 resumes. If your company has fewer than 150 employees or does not have a federal contract of at least $150,000, you should retain these records for one year. If you have at least 150 employees and a contract of $150,000 or more, you are required to maintain the records for a period of two years. However, any records pertaining to outreach to veterans and individuals with disabilities will need to be kept for a period of three years. As far as interviewing and selection, contractors are required to keep a record of any tests, test results, and interview notes. While there is no OFCCP requirement for contractors to use disposition codes, it is in the contractor’s best interest to use strategic disposition codes that record all of the following: • The stage in the selection process when the candidate was removed from consideration for the position • The reason for removing the candidate from consideration • The person who made the decision to remove the candidate from consideration If you are using a staffing agency and these positions will end up on your payroll, you need to make sure that the staffing agency is recording and retaining this data on your behalf; because ultimately, it is your responsibility as the contractor to provide proof of compliance. OFCCP has made it clear that the use of a staffing agency does not excuse a contractor of its obligations and that the contractor will be held accountable if records are not being kept. For more guidance on this topic, see OFCCP’s " target=_blank>Frequently Asked Questions on the Internet Applicant Recordkeeping Rule

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.