Internet Applicants

Has anyone had experience in recordkeeping under OFCCP's "new" internet applicant rule? I am wondering about a government contractor's obligation to check up on candidate search vendor's practice of retaining records? Do we have to ensure that they are following the rules? If we think that they aren't, what are our obligations? Any help would be very much appreciated! Thanks!


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  • I believe you have the regular obligation to inform them that you are a government contractor, and because they are working as a sub to perform the work of the contract (assuming that they are), then it is their obligation to comply with OFCCP's rules re: applicants, AA and recordkeeping. Beware, though, if you think that they are not complying with the rules (and have good reason to think so), you should address this with the vendor, remind them of their obligation and tell them that they must rectify, or you will change vendors. If they do not comply, you really must change vendors. Good luck!

  • I would actually be more aggressive and either get the search firm's guarantee that they are compliant with OFCC's rules in writing, or immediately hire a new search firm that can make this guarantee.
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