Last week we looked at how the Affirmative Action regulations' and OFCCP define an "applicant", or more specifically, an Internet Applicant, under the Internet Applicant Rule. (Click here if you missed that.)  It comes with significant recordkeeping requirements. If you are a federal (sub-) contractor, it therefore warrants your full attention. Suppose you, choose to use software to track individual applicants, resumes and other phases of pre-employment screening, aka an Applicant Tracking System (ATS). You could still encounter problems during OFCCP audits, though. Fines and penalties can be in the tens of thousands of dollars. You could even be debarred from working with the federal government.  What's causing these problems, and what can you do to ensure your practices –and your ATS– withstand OFCCP scrutiny?

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