EEOC Proposes to Clarify "Applicant" in the Electronic Age

The Equal Employment Opportunity Commission is close to clarifying the term "applicant" in the context of the internet and related electronic data processing technologies, e.g. e-mail, applicant tracking systems, electronic scanning, etc.  According to the soon to be implemented proposal, to be considered an "applicant" the following must have occurred:  1) the employer acted to fill a particular position, 2) the individual has followed the employer's standard procedures for submitting job applications and 3) the individual has indicated an interest in a particular position.  When effective, this clarification means that employers must track electronic job applications in the same way as hard-copy applications.