Assuming your company is using the internet applicant rule, the company must collect the data if the applicant receives an offer. (See rule below.) On those that did not receive an offer, unless the applicant withdrew during the selection process, the demographic data should be kept. Therefore, your instincts are correct. By the way, make sure to differentiate between status codes and disposition codes. Status codes identify where the applicant is in the process (e.g., "Interviewed") and dispositions identify why the individual was not hired, or that he or she was hired (e.g., "Not hired, late for interview" or "Offer declined") (It's possible your company has the disposition in the "sub-code," but it's worth mentioning here.) An “Internet Applicant” is an individual who satisfies all four of the following criteria: The individual submitted an expression of interest in employment through the Internet or related electronic data technologies; The contractor considered the individual for employment in a particular position; The individual’s expression of interest indicated that the individual possesses the basic qualifications for the position; and The individual, at no point in the contractor’s selection process prior to receiving an offer of employment from the contractor, removed himself or herself from further consideration or otherwise indicated that he/she was no longer interested in the position.

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.