OFCCP’s Internet Applicant Recordkeeping Rule requires federal contractors to save certain records when they conduct resume database searches, whether it is an internal or external database. When you are searching your own applicant tracking system as you described, you are essentially conducting an internal resume database search. The records you need to keep for internal resume database searches are as follows: • A record of each resume added to the database • A record of the date each resume was added to the database • A record of the position for which each search of the database was made • The date of the search for each search conducted • The substantive search criteria for each search conducted – such as experience, degree, location, industry, and key words used When you are searching other websites such as CareerBuilder, you are conducting an external resume database search. The records you need to keep for external resume database searches are as follows: • A record of the position for which each search of the database was made • The date of the search for each search conducted • The substantive search criteria for each search conducted – such as experience, degree, location, industry, and key words used • The resumes of job seekers who met the basic qualifications for the particular position who you considered for the position. You are not required to maintain the resumes of individuals if you did not consider them for the position. You are also not required to maintain a record of searches that do not produce candidates that meet the basic qualifications. When you are selecting from within the applicants who have applied to the position, you are required to keep a record of any tests, test results, and interview notes. While there is no OFCCP requirement for contractors to use disposition codes, it is in the contractor’s best interest to use strategic disposition codes that record all of the following: • The stage in the selection process when the candidate was removed from consideration for the position • The reason for removing the candidate from consideration • The person who made the decision to remove the candidate from consideration For more guidance on this topic, see OFCCP’s " target=_blank>Frequently Asked Questions on the Internet Applicant Recordkeeping Rule.

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.