Applicant Log

The OFCCP has recently begun enforcing a little used compliance provision requiring that employers provide detailed applicant logs upon request during OFCCP desk reviews or audits. To comply with such requests, the OFCCP is requiring that the employers provide the OFCCP examiners applicant logs covering both job seekers and applicants, either as separate logs or as a combined log. If separate logs are desired, which we believe is preferable after consulting with the OFCCP and a prominent law firm, the job seeker log must show the following information:

  • Candidate Name
  • Date of application
  • Job applied for
  • Location applied for
  • Race
  • Sex
  • Disposition

Disposition refers to whether the candidate remained a job seeker due to lack of qualifications.

If a job seeker has the minimum qualifications for the job and thus becomes a qualified applicant, then the above information must be retained for each applicant and a log must track and record the disposition of the applicant for each step of the selection process until the applicant is hired, rejected or voluntarily withdraws from consideration.

NOTE: The entire step by step process for both job seekers and applicants must be documented and provided in the respective log(s).

In addition to the data reflected above, the OFCCP is now requiring employers to also prove that they have a system in place to collect and retain the usual data required by the OFCCP in addition to that required by the applicant logs.

To address this compliance issue, we at CRI are incorporating a new Applicant Log capability into our Applicant Management Systems. This feature will allow users of the CRI Applicant Management System to easily generate the logs as requested by the OFCCP and eliminate the need to maintain applicant logs manually.