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OFCCP Issues "Internet Applicant" Definition


The Office of Federal Contract Compliance Programs ("OFCCP") issued a final rule on October 7, 2005, clarifying the definition of an "applicant" in the context of internet recruitment and amending recordkeeping requirements regarding internet applications. This long-awaited clarification narrows the applicant definition previously utilized by the OFCCP, but will require many contractors to modify existing data collection and recordkeeping practices by February 6, 2006, so contractors should initiate a comprehensive review of their selection, applicant tracking, and record retention processes promptly to ensure compliance with this new rule.

For more information, please contact the professional(s) listed below, or your regular Crowell & Moring contact.

Kris D. Meade
Partner – Washington, D.C.
Phone: +1 202.624.2854

Rebecca L. Springer
Partner – Washington, D.C.
Phone: +1 202.624.2569

Crowell & Moring LLP is an international law firm with approximately 550 lawyers representing clients in litigation and arbitration, regulatory and policy, and transactional matters. The firm is internationally recognized for its representation of Fortune 500 companies in high-stakes litigation, as well as its ongoing commitment to pro bono service and diversity, equity and inclusion. The firm has offices in Brussels, Doha, London, Los Angeles, New York, Orange County, San Francisco, Shanghai, and Washington, D.C.

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