Yes. For external resume databases, contractors must retain all expressions of interest considered for individuals who meet the basic qualifications for a particular position, even those of individuals who are not Internet Applicants. Contractor must maintain a record of : -Position for which each search was made -Substantive search criteria used in each search -Date of search -Resumes of any job seekers who met the basic qualifications for the particular position who are considered by the contractor (even if they do not qualify as 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.