The OFCCP's record keeping regulations allow you to maintain a database for internal use. To get the referrals into the system using an internal hire link is permissible. OFCCP's regulations (41 CFR Section 60-1.12) tell you that for purposes of record-keeping with respect to internal resume databases, the contractor must maintain a record of each resume added to the database, a record of the date each resume was added to the database, the position for which each search of the database was made, and corresponding to each search, the substantive search criteria used and the date of the search. The key going forward from there -- after you have added the referral to the database -- is to be able to track whether you actually considered the individual for a particular position when it becomes available, and if you are actually considering them for more than one position, to track them for each position for which you actually consider them. Your dispositions in each requisition will be important. If you attach the candidate to a requisition, and the hiring manager looks at the candidate and concludes that this candidate does not meet the basic qualifications for the opening, the disposition in that requisition should be "does not meet basic qualifications." If you send the resume/application out to another manager, and the manager thinks the candidate is qualified but does not want to interview the candidate, you will have to disposition it accordingly in that second requisition. A qualified candidate who is actually considered for a particular opening is counted in your adverse impact analyses unless the candidate withdrew prior to an offer of employment. If there are additional follow up questions on the topic, I would be willing to speak by phone.

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.