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Recruitment Compliance Audit Limits OFCCP Liability and Dramatically Improves Process

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The Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) is actively auditing federal contractors' recruitment processes against the Internet Applicant rule established in February 2006. It is imperative that companies proactively self-audit to determine potential areas of non-compliance limit liability and mitigate risk. OFCCP settlements concerning non-compliance can be in the millions of dollars with wide-ranging implications.

A multi-billion dollar professional services firm hoped to find a credible partner that could analyze its recruitment process and recommend enhancements to improve OFCCP compliance. The firm recognized that HRworks possesses Affirmative Action/OFCCP compliance audit expertise and provides recruitment support to Federal contractors.


The firm selected HRworks to conduct an audit of its recruitment processes, technology and third-party recruitment vendors. HRworks collaborated with the firm's recruitment department to analyze its recruitment processes and perform a gap analysis against the new OFCCP regulations regarding the definition of an Internet Applicant.

HRworks analyzed the recruitment process across a strategic spectrum of positions and situations. HRworks reviewed five requisitions filled by internal promotions or transfers, five positions filled by corporate recruiters with external candidates, as well as five hires from staffing agencies and executive search firms.

Using a systematic approach, the contacts for each of the positions were interviewed and asked detailed data analysis questions regarding each hire to determine if the proper records were maintained and OFCCP-compliant procedures were followed. In partnership with corporate legal, an impact-ratio analysis was conducted to quantify the potential risk and prioritize the action plan.


Upon completing the audit, HRworks collaborated with the firm, recommending improvements to internal and external practices that supported the business and Affirmative Action requirements. Additionally, HRworks made recommendations on recruitment technology solutions to facilitate a compliant recruitment process. HRworks vetted the firm's third party search firms for compliance, resulting in a reduced number of search firms and dramatically improved the entire recruitment process. HRworks supported recruitment in non-compliant areas to ensure the flow of talent continued throughout the organization while a more compliant recruitment process was implemented.

The audit of the recruitment practices and vendors helped limit liability and mitigated the risk of OFCCP settlements due to non-compliance with the Internet Applicant ruling. HRworks' recruitment enabled the firm to maintain recruitment while converting to best practices and compliant recruitment resources.

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