The record keeping obligation for federal contractors is stated under OFCCP’s Internet Applicant Rule here.
In 41 C.F.R. § 60-1.3 OFCCP defines who is an Internet Applicant and in 41 C.F.R. 60-1.12 it sets forth the record retention requirements for federal contractors.
According to the OFCCP, an “Internet Applicant” is an individual who satisfies all four of the following criteria: the individual submitted an expression of interest in employment through the Internet or related electronic data technologies; the contractor considered the individual for employment in a particular position; the individual's expression of interest indicated that the individual possesses the basic qualifications for the position; and the individual, at no point in the contractor's selection process prior to receiving an offer of employment from the contractor, removed himself or herself from further consideration or otherwise indicated that he/she was no longer interested in the position.
Contractors are not required to maintain the resumes of individuals if the contractor did not consider them. If the candidate does not meet the basic qualifications for the position, then you would not be required to maintain these records under the Internet Applicant Rule.
OFCCP also allows contractors to establish a protocol where it would refrain from considering expressions of interest that are not submitted in accordance with standard procedures the contractor establishes. Therefore, requiring applicants to submit an online application in order to be considered is acceptable. It is important that this protocol is documented in your hiring process and that you apply it in a uniform and consistent manner.
For more guidance on this topic, see OFCCP’s Frequently Asked Questions on the Internet Applicant Recordkeeping Rule here.