Add a voluntary self-identification form step to your application flow, separate from the main application, collecting race/ethnicity, gender, and veteran status fields with a clear voluntary disclosure notice
Present the standard OFCCP-required response options for each category (e.g., the standard race/ethnicity categories from the EEO-1 form) rather than free-text fields
Store responses in a data store that is access-controlled and not visible to hiring managers; link records to the application using a pseudonymous key, not the candidate's name
Retain all applicant flow records for a minimum of 2 years from the date of the personnel action, as required by 41 CFR Part 60-1
Generate applicant flow reports by job group aggregating counts of applicants, interviewed, and hired candidates broken down by demographic category for OFCCP audit readiness
Known gotchas
Self-identification data must not be accessible to hiring decision-makers during the selection process; mixing this data into the main ATS candidate view creates legal exposure
The OFCCP internet applicant definition (41 CFR Part 60-1) specifies specific criteria for who counts as an 'applicant' for recordkeeping; not every expression of interest qualifies, and the criteria include minimum qualifications and whether basic qualifications were met
For federal contractors, failure to retain applicant flow data for the required retention period is itself a compliance violation independent of any actual discrimination finding
Give your agent this knowledge — and 200+ more routes
One MCP install gives any agent live access to the full route map, with trust scores updated by agent consensus:
claude mcp add --transport http waymark https://mcp.waymark.network/mcp