1. PURPOSE

This policy establishes standards for the collection, use, storage, and communication of applicant data in compliance with federal contractor obligations and applicable federal and state laws.

2. SCOPE

This policy applies to:

• All job applicants and candidates
• All employees involved in recruiting and hiring
• All systems used for recruiting, including Paylocity ATS

3. APPLICANT PRIVACY POLICY

3.1 Information Collected

The Company collects the following categories of information:

• Personal identifiers (name, address, phone, email)
• Employment and education history
• Resume and qualifications
• Background screening information (where permitted)
• Voluntary EEO/affirmative action data
• System and device data from ATS usage

3.2 Use of Information

Applicant data is used to:

• Evaluate qualifications
• Communicate regarding job opportunities
• Conduct background checks post-offer
• Comply with federal contractor reporting obligations
• Maintain recruiting records

3.3 Equal Employment & Data Separation

Voluntary demographic data is:

• Collected solely for compliance purposes
• Maintained separately from hiring decision-makers
• Not used in employment decisions

3.4 Data Sharing

Data may be shared with:

• Background screening vendors
• Paylocity and related service providers
• Government agencies as required

The Company does not sell applicant data.

3.5 Data Retention

Applicant data will be retained:

• In accordance with federal contractor requirements (minimum of 2 years unless otherwise required)
• As required by applicable law

3.6 Data Security

The Company maintains reasonable safeguards to protect applicant data.

 

4. BACKGROUND CHECK COMPLIANCE (FCRA)

4.1 Disclosure

A standalone disclosure will be provided prior to conducting a background check.

4.2 Authorization

Written authorization must be obtained before initiating any background screening.
 

4.3 Pre-Adverse Action

If adverse action may be taken:

• Applicant will receive pre-adverse notice
• Copy of report and summary of rights provided

4.4 Adverse Action

If final adverse action is taken:

• Applicant will receive adverse action notice

5. TEXT MESSAGE (SMS) POLICY

5.1 Consent Requirement

Applicants must provide affirmative consent before receiving text messages. The Company utilizes Paylocity ATS to administer SMS consent and disclosures.

5.2 Permitted Uses

Text messages may be used for:

• Interview scheduling
• Application updates
• Job opportunity notifications

5.3 Opt-Out Management

• STOP requests must be honored immediately
• Opt-out records must be maintained

5.4 Recordkeeping

The Company will maintain:

• Timestamp of consent
• Method of consent
• Version of disclosure presented

6. PAYLOCITY ATS ADMINISTRATION CONTROLS

6.1 Access Controls

• Access limited to authorized personnel
• Role-based permissions enforced

6.2 Audit Trail

• All applicant activity must be logged within Paylocity
• Changes to applicant status must be documented

6.3 Disposition Codes

• All applicants must be dispositioned
• Disposition reasons must be job-related and consistent

6.4 Recordkeeping

• Applications and hiring records must be retained per policy

7.1 Applicant Data and Rights

Applicants may request:

• Access to their data
• Corrections where applicable
• Access to collected data
• Deletion where permitted by law

8. FEDERAL CONTRACTOR REQUIREMENTS

The Company will:

• Maintain applicant flow data
• Track job postings and hires
• Retain records for audit purposes
• Ensure non-discrimination in hiring practices

9. NON-DISCRIMINATION

All hiring decisions will be based on legitimate, job-related criteria. The Company prohibits discrimination in accordance with all applicable laws.

 

10. RESPONSIBILITIES

HR / Recruiting

• Ensure compliance with this policy
• Maintain accurate records
• Administer Paylocity ATS

Hiring Managers

• Follow structured hiring practices
• Document hiring decisions appropriately

IT / Systems

• Maintain security and access controls

11. CONTACT INFORMATION

Questions regarding this policy should be directed to: Jordan Elsamiller, HR Director.
 email: Jordan.Elsamiller@doerfer.com
 phone: (319) 483-4700

 

12. ACKNOWLEDGMENT

All employees involved in recruiting must comply with this policy.

 

13. OFCCP COMPLIANCE ADDENDUM

13.1 Internet Applicant Rule

The Company will define and track “Internet Applicants” consistent with federal contractor requirements. An individual is considered an Internet Applicant if they:

• Submit an expression of interest through the ATS or other electronic means
• Are considered for a specific position
• Meet the basic qualifications for the position
• Do not remove themselves from consideration prior to receiving an offer

13.2 Applicant Flow Logs

The Company will maintain accurate applicant flow data within Paylocity ATS, including:

• Job requisition information
• Applicant status changes
• Disposition codes and reasons
• Source of application

13.3 Record Retention

The Company will retain the following records for a minimum of two (2) years (or longer if required):

• Job postings and advertisements
• Applications and resumes
• Interview notes
• Disposition records
• Hiring decisions and supporting documentation

13.4 Job Posting Requirements

• All positions must be posted in Paylocity ATS
• Job postings must include required equal employment opportunity statements
• External job listings must be documented and retained

13.5 Disposition Codes

• All applicants must be dispositioned
• Disposition reasons must be job-related, consistent, and non-discriminatory
• Recruiters and hiring managers must avoid subjective or vague disposition language

13.6 Data Integrity

• Applicant data must be complete and accurate
• Changes to applicant status must be recorded in real time
• Audit trails must not be altered or deleted