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ARTICLE · 08 FEBRUARY 2006

OFCCP Issues New Rule on Internet Applicants

Sutherland Asbill & Brennan LLP
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The Department of Labor’s Office of Federal Contract Compliance Programs ("OFCCP") has issued a new rule amending its record-keeping and impact analysis requirements for federal contractors and subcontractors with regard to internet-based job applicants.

United StatesEmployment and HR
Lisa Jern
Lisa Jern
Nicholas Christakos
Nicholas Christakos
Allegra Lawrence-Hardy
Allegra Lawrence-Hardy

Originally published February 6, 2006

The Department of Labor’s Office of Federal Contract Compliance Programs ("OFCCP") has issued a new rule amending its record-keeping and impact analysis requirements for federal contractors and subcontractors with regard to internet-based job applicants. The rule goes into effect today and includes the agency’s first official definition of an "internet applicant."

This new rule is significant. While it may greatly expand record-keeping burdens for federal contractors and subcontractors, it also clarifies that these contractors may avoid significant record-keeping burdens by limiting consideration of expressions of interest under an established protocol, as discussed below. Federal contractors now have an opportunity to scrutinize their hiring protocols and revise existing policies where possible to avoid unnecessary record-keeping burdens.

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