OFCCP Applicant Data Examination
According to Berkshire, companies selected for audit by the OFCCP will have to submit their applicant data by job group. In analyzing these data, the following 7 questions may be asked by OFCCP:
Why is the hire date before the application date?
Why are applicant pools missing for some requisitions?
Why are some new hires missing in the applicant data?
Do you include internal hires in your applicant flow?
Why are multiple job titles filled under one requisition?
Can you show proof you have posted your jobs with an Employment Service Delivery System (ESDS)?
Do you conduct adverse impact analysis on applicant data?
Their point is that accurate applicant tracking is essential for companies who must file AAPs, and they note that an automated applicant tracking system could be a significate benefit in this regard.