What you described here sounds more like creating an internal database of prospective candidates for future positions at your company. In that case, you need to make sure that you are following the record retention requirements under OFCCP’s Internet Applicant Recordkeeping Rule. Federal contractors are required to save records when they search a resume database, whether it is an internal or external database. For internal resume database searches, you will need to keep a record of the following: • 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 If you are reaching out to individuals within this database for your openings, you need to ensure that you have a standard written policy that describes your hiring process, the criteria you use to select from this database, and the requirement that interested individuals must submit an application in order to be considered for a job. The risk that you have here is that, depending on how things are practiced, you may get into a situation where this large pool of individuals could be considered as your entire applicant pool for each of your jobs. There is a greater chance of generating false positives in bigger numbers, so you will want to keep your applicant pool to smaller numbers. Thus, having a documented policy that is implemented consistently will help minimize that risk. Keep in mind as well that if you are a federal contractor covered under VEVRAA and Section 503, your company has an obligation to post your open positions to the state ESDS and conduct outreach. Any applicants that are generated from those efforts that meet the Internet Applicant definition will also be considered part of your applicant pool.