While I know your consideration for job seekers is well meant, it will get you in trouble! And no, you can't just ask "permission" from the job seeker to "transfer" him or her to another requisition for which s/he is a "better fit". THAT is a SELECTION. Think of it this way: by considering John Doe for TWO positions you have doubled his chances to be hired. But you are not ALSO giving all the Jane Does who expressed interest in the same job as did John the same second bite at the apple; you have simultaneously REJECTED -- DENIED each of them TWO job opportunities. Unless you are prepared to count ALL of the job seekers who sought Job A in your computations and selection process for Job B, you MUST put the responsibility on the job seeker. You may lawfully "recruit" for Job B only those job seekers from the Job A requisition that you would like to consider for Job B by encouraging them to apply for Job B; anyone else still has an "equal opportunity" to apply for that posted Job B. But you may not "consider" any -- that is make an evaluation of their qualifications for the second job -- unless they apply for it. Putting the "work" on the job seeker is exactly what you must do. Perhaps your tech people can assist in simplifying the process -- i.e. by populating the new expression of interest form with information from the initial expression of interest ??? -- but it is VERY important that the employer NOT treat applications as fungible. An "expression of interest" BY THE JOB SEEKER starts the selection process and the required record keeping for each opportunity. Frankly, I can't imagine someone who really wants to work for you being unwilling to complete a little more "paperwork" when specifically invited by the employer to do so! Some additional food for thought...While you probably permit all job seekers to apply for multiple open positions -- or subsequently open requisitions -- the contractor's compliance obligations (including ever expanding record keeping and vulnerability to challenge of selections!) should greatly limit any impulses to extend "career counseling" to job seekers! AND it is perfectly lawful to limit the number of applications/expressions of interest that a single job seeker has in play at any one time. It's worth emphasizing that ALL policies and procedures should inure to the benefit of the EMPLOYER. Every person who is rejected/not selected FOR EVERY OPPORTUNITY for which s/he was considered has the potential to allege unlawful discrimination. It may well be in the employer's interest to undertake that risk multiplied by three or five or X requisitions but, in my experience, every employer should also have SOME limit on the number of active applications permitted for a single individual.
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.