OFCCP’s Recent FAQ Clarifies How Contractors May Document Invitations To Self-Identify

As part of its ongoing effort to answer questions concerning last year's Section 503 regulations, OFCCP recently posted a new FAQ that highlights how contractors may document compliance with the requirement to invite applicants and employees to self-identify a disability.  The FAQ clarifies how contractors may store the invitation to self-identify and the subsequent data flowing from either a paper or electronic invitation.

First, if contractors use paper copies of the OFCCP self-identification form, either the hard copies or electronic copies (such as PDFs or scanned files, among others) of the completed paper form must be retained.  Additionally, contractors must retain any logs, spreadsheets, or databases developed to record the resulting data from the self-identification form.