Applicant Tracking Dispositioning for Federal Contractors Carla Irwin

Applicant Tracking & Dispositioning for Federal Contractors Carla Irwin & Associates, Inc.

Agenda • • • OFCCP Definition of an Internet Applicant Disposition Codes Recordkeeping Requirements Protocols for All Sources Why? Resources

Definition of Internet Applicant 1. Individual submits expression of interest through Internet or related electronic technologies; and 2. Contractor considers individual for employment in a particular position; and 3. Individual’s expression of interest indicates basic qualifications for the position; and 4. Individual does not remove him/herself from consideration prior to job offer

Expression of Interest • Related Electronic Technologies (can include, but not limited to) – Email – Job banks – Applicant tracking systems – Fax – Scanning • Accept both electronic & paper, internet applicant rule applies

Considers • “Considers” mean assessing the job seeker’s qualification relative to the particular position • Contractor allowed to establish protocols for submission of interest • Contractor allowed to establish protocols for considering expressions of interest – Data management technique – Unsolicited resumes

Data Management Technique When dealing with a large number of expressions of interest, contractor may use data management techniques, that do not depend on qualifications, to reduce the number considered. For example: • Random sampling • Absolute numerical limits

Basic Qualifications 1. Noncomparative 1. Number of years experience vs. top 5 most experienced 2. Objective 1. Bachelor’s degree vs. good school 3. Relevant 1. To performance of position 4. Must be advertised or established in advance

Continued Interest What is a lack of continued interest? • Express statement of disinterest (verbal or written) • Failure to respond to inquiries (at least 2) • Statements made in the expression of interest indicating: – Incompatible salary requirements – Incompatible preferences as to position or type of work – Incompatible preferences as to location of work

Disposition Codes • • • Requisition cancelled Did not consider due to data management techniques (DMT) Did not meet Basic Qualifications • – Phone interview - no further consideration (provide reasons or multiple codes here, such as industry experience, years of experience, type of experience, education, etc) – Did not pass required tests – Not Best Qualified – Industry Experience – Not Best Qualified – Amount of Experience – Not Best Qualified – Type of Experience – Not Best Qualified – Education – Not Best Qualified – Technical Skills – Did not meet BQ’s - Years of experience – Did not meet BQ’s - Education/certification – Did not meet BQ’s – Technical Skills • Candidate Withdrawal – Withdrew application (provide reasons, or multiple codes, such as, lost interest due to job duties, geography, pay, shift/hours, staying with current employer, etc. ) – Falsification of information – Pre-offer Candidate not eligible for rehire – No show for interview – Did not return phone calls/could not contact – Incomplete application/Did not follow application process – Indicated salary request did not meet expectations Met Basic Qualifications – Not Selected • Selection Codes – – – – Declined Offer Post-Offer – Failed drug test/physical Post-Offer – Failed background checks Late Lie – Discovered Post-offer No Report – Never showed up for work Hired Internal candidate

Recordkeeping • • Soliciting race/gender/ethnicity Expressions of interest Internal database searches External database searches

Soliciting Demographic Info • Contractors are required to solicit race, ethnicity, and gender data from all individuals who meet the four criteria of an “internet applicant”. However how and when is left up to the contractor. • You can voluntarily collect demographic data from all job seekers even those who do not meet the 4 prong definition, as long as such information is used only for purposes of the contractor’s AA & EEO programs. • Must also solicit demographic info on all individuals who take employment tests.

Recordkeeping – Expressions of Interest • Must keep all expressions of interest through the Internet or related technologies where the individual was considered for a particular position, except for expressions of interest from external resume databases.

Record Retention – External Database External database Search – Must maintain record of: • • Position for which each search was made Substantive search criteria used in each search Date of search Resumes of any job seekers who met the basic qualifications for the particular position who are considered by the contractor (even if they do not qualify as Internet Applicants)

Record Retention – Internal Database Search – Must maintain record of: • • • Each resume added to database Date each resume was added Position for which each search was made The substantive search criteria used in the search Date of the search

Recordkeeping – Record Retention • Employment records (interview notes applications, resumes, etc. ) internal/external database searches, demographic info, tests/test results, etc. • Companies with fewer than 150 employees or a contract less than $150, 000 – 1 year • Companies with more than 150 employees and a contract of $150, 000 or more – 2 years • Recordkeeping obligation belongs to federal contractor, cannot be delegated

Protocols for All Sources • • • Applicant Tracking System External Database Search Firms Employee Referrals Campus Recruiting/Job Fairs Unsolicited Resumes

Why? Analyzing Adverse Impact • Good documentation and recordkeeping key to accurate analysis and management of adverse impact – Detailed and documented disposition codes • Capturing candidate withdrawals • Reasons for rejection – Good notes in file – Managing size of applicant pool through DMT – Well designed Basic Qualifications – Good search criteria – Retain test and test results

Resources • Internet Applicant Rule http: //www. dol. gov/ofccp/regs/compliance/faqs/iappfaqs. htm#Q 1 RKa • OFCCP Internet Applicant FAQ http: //www. dol. gov/ofccp/regs/compliance/faqs/iappfaqs. htm • Recent OFCCP Cases http: //www. dol. gov/opa/media/press/ofccp/OFCCP 20111521. htm http: //www. dol. gov/opa/media/press/ofccp/OFCCP 20110799. htm http: //www. dol. gov/opa/media/press/ofccp/OFCCP 20111291. htm

Contact Info Carla Irwin & Associates, Inc. Email: cirwin@hrlinkgroup. com Phone: 815 -254 -0690 Website: www. carlairwininc. com