Like our site's new design? In April 2023, Circa was acquired by Mitratech.
>> Learn More

Expectations around record keeping for database searches, “good” and “bad” searches

Anonymous - April 5, 2021
Back to Ask the Experts


We understand as a federal contractor that we have to maintain records of the searches our recruiters do of “external resume databases” like LinkedIn. I’m trying to get more information on what exactly the OFCCP is looking for when reviewing or auditing those search records. What would be considered a “good” search? What search criteria would raise a red flag? We also recognize that some of our recruiters might be using resume databases to conduct “outreach” via search criteria like “veteran/military” or membership in a particular affinity group like black professionals from that field, etc. but I worry about the line between “outreach” and “considering race etc.” when sourcing for candidates. I’d like to provide our recruiters with some “best practices” around what search criteria they do (and don’t) use when sourcing candidates through sites like LinkedIn and would love some guidance.


1 Answer

Our Experts

Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.

Ahmed Younies

President and CEO, HR Unlimited, Inc.

Alissa Horvitz, Esq.

Member Attorney, Roffman Horvitz, PLC

Allen Hudson, PHR, SHRM-CP

CEO, HudsonMann

Angel Fischer

Angel Fischer

Bill Osterndorf

Principal Consultant, DCI Consulting Group, Inc

Carla Irwin, Esq.

President, Carla Irwin & Associates, Inc.

Craig Leen

Board Member, Circa

David Cohen

President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Julia Mendez Achee

Senior Consultant - EEO/Affirmative Action Division, Biddle Consulting Group

Lisa Kaiser, Esq.

Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

Roselle Rogers

Vice President, Diversity, Equity, and Inclusion, Circa

Stephanie Stahr

Senior HR Consultant, Berkshire Associates

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

Skip to content