As a general rule, you should avoid manually entering candidates into your ATS. Candidates should be required to apply, even if they're expressing interest in positions you don't currently have open. When you manually enter candidates into your system and then consider them for openings, you potentially create problems by violating your own rule that says that candidates must express interest in order to receive consideration for an opening. In your specific scenario, if there are 30 candidates you've looked at on a job board, and you require candidates to apply into your ATS in order to receive further consideration, and only 20 apply for your opening, these are the only candidates you would show in statistical and other reports that would be submitted to OFCCP. (In technical terms, only these 20 candidates would potentially be considered "Internet Applicants," since they are the only candidates who followed your process to receive consideration.) Unfortunately, the Internet Applicant rule doesn't let you fully discard information on the remaining 10 candidates. The rule has two major components: a component that tells you which candidates should appear in reports to be provided to OFCCP, and a component that tells you what materials (including resumes and other candidate materials) must be retained by your company. When you do a job board search, you must retain the following: - a record of the position for which the search was made - the substantive search criteria used - the date of the search - the resumes of job seekers who met the basic qualifications for the particular position who are considered by the contractor Note that your are not required to add all of these resumes to your ATS. You simply need to find a way to retain the resumes of all candidates who were considered, so long as they met the basic qualifications for your position. In this situation, "consideration" means that you may any substantive review of the qualifications of the candidate. Thus, in your example above, the 20 candidates who applied for your opening potentially become part of the dataset that would be provided to OFCCP during a compliance review, and the 10 candidates who did apply should NOT become part of your ATS but SHOULD have their resumes retained if they met the basic qualifications for the open position and were given any kind of substantive consideration.

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.