Yes. I would absolutely recommend documenting this very well. This practice could expand the applicant pool in an audit, so it needs to be documented well, including, but not limited to, how long applications in the pipeline remain active, for what jobs, and the process for establishing who to contact and what the process is to notify them of an opening. I'd recommend talking thru the specifics a bit with your labor counsel.
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.
