Hi Ethel, The OFCCP Internet Applicant Rule, which seems to apply based on your description above, requires the data be collected when the individual is considered (as well as expresses an interest, does not self-withdraw prior to offer, and is minimally qualified). So, if the individual in your example above meets those four prongs, then the company must collect the EEO data. If the company requires individuals to submit an application through its website to be hired, then failure to do so could be considered self-withdrawal. EEO data must be collected before the offer stage (as well as after). At what point an individual fills out an application is of no consequence to OFCCP compliance and soliciting demographic data. Hope this helps!

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