The regulations under EO 11246 do not indicate that pre-screening/interview notes need to be maintained within the ATS. However, the OFCCP does expect contractors to maintain interview notes in some format for the required record retention period which is typically two years depending on the size of the company and amount of the federal contract. The OFCCP has posted FAQs regarding the internet applicant at the following site: https://www.dol.gov/agencies/ofccp/faqs/internet-applicants

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.