OFCCP issued a Frequently Asked Question on this topic. In the FAQs for Section 503 (Rehabilitation), under the topic of Self-Identification, #5, OFCCP gives employers the option to store the electronic record and print it out if requested. There is no requirement to print out a hard copy of each form and store it in hard copy in separate files as was done in the past: FAQ5. What information must a contractor store in order to demonstrate its compliance with the requirement to invite voluntary self–identification of disability from applicants and employees? OFCCP's ANSWER: Recognizing that contractors may have different practices and information technology capabilities, OFCCP is providing a range of options for documenting compliance with the voluntary invitation to self–disclose disability requirement. Electronic Invitations. A contractor that electronically invites voluntary self–identification of disability must either: o Retain electronic copies (e.g., pdf, scanned, etc.) of the electronically completed self–identification forms, as well as any log, spreadsheet or database it may have developed to record the data from the self–identification forms; o Retain hard copies of the electronically completed self–identification forms, as well as any log, spreadsheet or database it may have developed to record the data from the self–identification forms; or o Retain a detailed log, spreadsheet or database of the data collected from each electronically completed form, without copies of each individually completed form, if the electronic system does not store completed forms. However, the contractor must also be able to demonstrate how they delivered and/or displayed the voluntary invitation to self–identify. This allows compliance officers to verify that contractors met their obligation to use the OMB–approved form.
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.