The regulations that govern federal contractors or EEO for that matter, do not prescribe procedures that specify how employers should structure their hiring process. Federal contractors and subcontractors have a lot of latitude in defining their selection and hiring process, as long as the process ensures compliance with your affirmative action, nondiscrimination, and recordkeeping obligations. Your obligations may also vary depending on whether you are covered under one or more of the three regulations OFCCP enforces. You can find detailed information on your affirmative action obligations in this Supply and Service Technical Assistance Guide from OFCCP. In evaluating your process, you would want to make sure your process gives you the ability to determine who is an internet applicant for adverse impact analyses. You can find a definition of who is considered an internet applicanthere.