Depending on whom you ask, you’re likely to get a range of opinions and justifications. From a candidate’s perspective, the answer is going to be a resounding, “Are you kidding me, of course! That’s why I took time to attend this career fair in the first place.” However, ask 10 recruiters and you’ll get as many opinions from the philosophical to the pragmatic. Phrases such as “non-compliant,” “increased workload,” “retention period,” “my memory aid,” and “free kindling” are sure to come up.

From a practical perspective, there is quite a bit of confusion as to whether a recruiter can or shouldn’t take resumes at career fairs. If you fall under the scrutiny of OFCCP (Office of Federal Contract Compliance Programs), you’re likely to feel accepting resumes is the modern day equivalent of walking the plank. So how did we end up becoming so confused about a fairly straightforward process of accepting a sheet of paper? Without doing an extensive historical study, we can assume the practice of accepting paper resumes dates back to when career fairs first came into existence.  During this rather blissful and largely “compliance-free” period in recruiting history, recruiters gladly accepted candidate’s paper bios. Some even speculate the green movement got its start in recruiting as environmentally concerned recruiters took great pains to write their notes on candidate’s resumes rather than waste additional paper. All was copacetic in the land of recruiting…well okay, so there was that stack of paper to deal with post-event, but we’ll deal with this in another blog.

But alas, all good things must come to an end. A perfect storm of technology in the form of applicant tracking systems (ATS) and government efficiency (can you say oxymoron), otherwise known as OFCCP, converged to cast a dark shadow on this once glorious practice – though which came first is the subject of heated debate. Suddenly, terminology like “Internet Applicant”, “Internet Applicant Rule,” “expressing an interest,” “false positives,” “tracked searches” and the two most dreaded words ever uttered in HR – OFCCP Audit – entered the lexicon of recruiting.  If you’ve ever had the misfortune of being on the wrong side of an OFCCP audit, it’s no wonder why companies adopt a “no resume policy” at career fairs, even though it’s akin to throwing the baby out with the bathwater. However, just because a company may have failed an audit doesn’t mean the practice of accepting resumes should be shunned altogether.

The reason is that from a compliance standpoint, accepting resumes at career fairs is absolutely encouraged by the Department of Labor. In fact, the OFCCP clearly states on their website that 1) accepting resumes is acceptable, and 2) resumes do not have to be retained so as long as prospects are NOT considered for a single position AND are directed back to the career website to apply. In other words, consistency in process execution is the key here.  So, from a factual or compliance point of view, accepting resumes is an okay.

However, with great power comes great responsibility and this is why we tend to see variations in how recruiters view the subject of accepting paper resumes.  For employers, this means being exceptionally diligent in policing their processes, ensuring all staff are properly trained BEFORE heading out to a career fair, clearly communicating when paper resumes can/should be accepted, and when they absolutely must be retained. This is fairly straightforward when the team is fairly small, but in the real world, dozens if not hundreds of “recruiters” are now relied upon to execute the strategy. And therein lies the problem. What tends to get companies into the cross-hairs of OFCCP auditors is that even though a company may have a well documented policy, it is a company’s actual practice of how they select talent that determines if it has met the spirit of the law – translation – we can’t trust hundreds of staff to do this correctly all the time, every time.  And so to minimize their risk of a failed audit, companies will retreat to a “safe haven” of not accepting resumes and directing interested candidates to visit their website. Never-mind that on average, perhaps no more than 10% of career fair attendees will actually follow through to visit a company’s website. The predominant thinking is – “At least we’ll be compliant.”

Up Next: Best practices for adopting a ‘paper resumes accepted here’ philosophy.

About the Author

Steve Tiufekchiev – Chief Evangelist

Steve Tiufekchiev was a recruiting professional with extensive experience in the university recruiting (UR) side of Talent Acquisition until his geek gene got the better of him. With his passion for technology and his decades of expertise in UR, he’s helped RECSOLU become the most recognized name in event-centric recruiting. Today, his visionary quest is to transform the candidate and recruiter experience with innovative technology, validate recruiting strategies with insightful data and transform decades old candidate and recruiter experiences with innovative technology. You can follow him on Twitter.