Since this is a question about privacy versus OFCCP compliance, it is a bit out of my area of expertise, but I want to give you some information at least, from a compliance perspective. Any time a company is reviewing job qualifications, it is important to understand why the criteria are what they are. In other words, why is a 3.1 acceptable for a new hire, but not a 2.9? What is the definition of "did well" in engineering classes? Seeing the transcripts could create a bias, but that doesn't mean that hiring managers cannot access them. You would definitely want to keep an eye out for trends that may be of concern, such as favoring one institution over another and that has adverse impact against a particular group. If transcripts are not required for each applicant to continue in the hiring process, why are they necessary for any one candidate? In short, I would recommend you review your hiring process and make sure that each step is required and useful in finding qualified applicants. You may also want to talk with your hiring mangers and ask them to articulate why they are requesting transcripts. If there is a genuine need, then it is probably a good idea to let the candidate know the transcripts may be used by the interview team. Hope this helps.