Even though the OFCCP has provided federal contractors with guidelines to define their applicant pool, the nuances underlying the Internet Applicant Recordkeeping Rule are challenging to think through. One question many contractors have in particular is, “What do we do with resumes received from job seekers at career fairs?”
A new posting on the OFCCP’s website provides an answer for such a concern:
If the Internet Applicant recordkeeping standards apply to hiring for a particular position and the contractor receives paper resumes for the position from job seekers at a career or job fair, does the contractor need to retain the paper resumes received?
The contractor needs to retain resumes only if it considers resumes received at the job fair for a particular position. The contractor need not retain any resumes if its consistently applied practice is not to consider paper resumes received at a career or job fair. For example, the contractor would not need to retain paper resumes offered at a job fair if it does not consider them and instructs all job seekers to post their resumes on the contractor’s web site and/or apply for particular positions on the web site. The contractor should take care to apply such a protocol in a uniform and consistent fashion. It is the contractor’s actual practice that determines whether the contractor has considered a resume. For example, if a contractor’s policy is to accept resumes only through its website, but its actual practice is to consider resumes received at a career or job fair as well, the contractor will be expected to retain both the resumes collected at job fairs as well as those submitted through the contractor’s website.
If you have questions about applying the OFCCP’s Definition of an Applicant to your applicant pool, bookmark the OFCCP FAQ’s for future reference, or give Biddle a call – we’d be happy to help point you in the right direction.
John Piatt jpiatt@biddle.com 800-999-0438, ext. 118 |
Nancy Tipton ntipton@biddle.com 800-999-0438, ext. 175 |