Identifying and Correcting Recordkeeping Violations Created via Applicant Tracking System Integrations

If your company accepts applications from job search engines such as LinkedIn, ZipRecruiter, Indeed, CareerBuilder, Monster, Simply Hired, or others, please read this urgent message.

Search Engine Applications Missing Required Voluntary Self-Identification Forms for Federal Contractors

There has been a spike in missing applicant voluntary self-identification forms (race/ethnicity, gender, veteran, and disability forms) across the federal contractor community that has resulted from increasing integrations between job search engines and applicant tracking systems such as Workday, Paycor, iCIMS, ApplicantPro, BambooHR, Paycom, etc. These applicant tracking systems provide companies the ability to automatically post open positions to job search engines, however companies often do not realize these integrations may fail to provide required self-identification forms to applicants. Kairos has noticed many instances where the integration between applicant tracking systems and job search engines results in companies failing to collect self-identification forms, which often goes unnoticed until companies submit their affirmative action plan data.

Potential Violations of Recordkeeping Regulations

Federal contractors & subcontractors who fail to provide self-identification forms to applicants are in violation of Federal Regulations at 41 CFR 60-1.12(c), 41 CFR 60-741.42(a), and 41 CFR Part 60-300.42(a).

Steps to Confirm Whether You’re Compliant with Federal Recordkeeping Obligations

  1. Determine if your company accepts applications from search engines such as LinkedIn, ZipRecruiter, Indeed, CareerBuilder, Monster, Simply Hired, etc.
  2. If your jobs are posted to job search engines which include button options such as “Apply Now”, “Quick Apply”, “One-Click Apply”, or “Easy Apply”, they will in most cases bypass your applicant tracking system self-identification forms since applicants apply directly through the search engine (search engines do not collect self-identification information).
    • If you discover you are not providing self-identification forms to applicants who apply through search engines, correct this as soon as possible by directing applicants to your website/applicant tracking system or reach out to Kairos to assist you with correcting this problem.
    • A small number of companies have successfully integrated self-identification forms into search engines such as Indeed (see example at bottom of post), but it is critical to confirm the solicitations are compliant and the data submitted can be exported for each applicant to the company’s applicant flow log.
  3. If your jobs are posted to job search engines, ensure they allow applicants to apply through your website/applicant tracking system OR that you integrate the self-identification forms into the search engine application as noted in step 2. Examples of correct button options include: “Apply on company site”, “Visit company website to apply”, or a simple “apply” link which takes the applicant to your company website/applicant tracking system, providing the applicant with the necessary self-identification forms (see example buttons below).

IMPORTANT NOTE: We’ve observed companies that have a combination of compliant and noncompliant application options built into search engines so it’s critical you review postings from each job posting source used to ensure compliant recordkeeping practices are in place.

Noncompliant Button Examples

Compliant Button Examples

Example Integration of Self-Identification Question (partial) in Indeed 

Contact Us for Assistance

Please do not hesitate to reach out to Kairos if you have any questions about your company’s practice of receiving applications from job search engines.

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