When performing resume searches on an external resume database, contractors must maintain the following records: 1) a record of the position for which each search was made, 2) the search criteria used that corresponds to each search, 3) the date of the search, and 4) the resumes of those job seekers who met the basic qualifications for the particular position who are considered by the contractor. However, contractors are not required to maintain the resumes of individuals if the contractor did not consider them. Contractors are also not required to maintain a record of searches that do not produce candidates that meet the basic qualifications. Contractors should also retain these records for a specified length of time depending on the size of the company and the contract it holds. For companies with fewer than 150 employees or a contract of at least $150,000, the record retention period is one year. Contractors with at least 150 employees and a contract of $150,000 are required to maintain the records for a period of two years. For more guidance on this topic, see OFCCP’s Frequently Asked Questions on the Internet Applicant Recordkeeping Rule
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.
