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Demographic Data Collection – Withdrawn Applications

Anonymous - Oct 11, 2018
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Good morning,

My question is in regard to collection of demographic data for OFCCP auditing purposes. Currently, our applicant tracking system allows applicants to “withdraw” their application at any point. This is true even if the applicant has been fully dispositioned and their application is no longer active. For example, if their application status is “Interviewed – Not Hired”, they may withdraw.

That being said, my question is as follows:

“In instances where applicants have been fully dipsoisitioned (a reason was designated for non-selection) and the applicant subsequently withdraws, would their demographic information still need to be part of the OFCCP report?”

My thought is “yes” given that not including their demographic information would improperly skew the analysis. For example, let’s say five applicants were interviewed. One person receives the offer and four receive the “Interviewed – Not Hired” disposition (which of course has it’s own sub-reason codes). If all four of the non-selected applicants withdraw and we omit their information, the analysis may incorrectly show that only one person was ever interviewed.

What are your thoughts?

Thank you, in advance, for the information.

1 Answer

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Former Deputy Director, OFCCP Partner, McGuireWoods LLP

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Manager, Consulting Services, Affirmity

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