Compliance Enablement Preferences

When the Anonymize personal applicant data for New Submissions option is selected, applicant data is made anonymous for applicants in a New Submission status. This setting is retroactive; thus, any new submission applicants, including existing new submission applicants, are made anonymous.

If this option is unselected, all applicant data is no longer anonymous. Note: If the Require OFCCP Compliance Enablement functionality option is selected, then this option is unselected and disabled.

Note: When the Skip New Submission Status option is checked in Requisition and Applicant Preferences, the Anonymize personal applicant data for New Submissions option is disabled and hidden. The option is hidden at the top level organizational unit (OU) and all child OUs.

This option is unchecked by default. The Anonymize applicant data after a period of inactivity option enables administrators to anonymize external applicants who have not accessed their career site My Profile page for a set number of days. Anonymizing an applicant means that the applicant's data will be permanently purged from the Applicant Tracking System (ATS) and will not be accessible by the you or Cornerstone.

To configure this option:

1. Select the Anonymize applicant data after a period of inactivity option. This enables the period of inactivity to be defined.
2. Define the period of inactivity in the Anonymize applicants data after field. Enter the period of inactivity in the numeric text field, up to three numeric characters. This is a required field.
3. Select either "Days" or "Months" in the drop-down. If "Days" is selected, then the applicant is anonymized after the set number of days of inactivity. If "Months" is selected, then the applicant is anonymized after the set number of months of inactivity. Note: Inactivity is defined as the applicant not accessing their profile on the career site for the number of days or months defined in the Anonymized applicants data after field.

Exclusions

If a candidate is in an open status for an open requisition, they will not be anonymized regardless of their period of inactivity. The reason for this is that a recruiter may still be considering the candidate and want access to their information. An open status is not limited to New Submission; it is any status other than Closed. If a candidate is in an open status when the requisition is closed, then they will be anonymized after the designated time period.

In addition, regardless of a candidate’s period of inactivity, they will not be anonymized if they are in a Hired status. This is because there could be a latency between when a candidate is moved from Hired to an internal employee. A recruiter would not want to lose the candidate’s information during that time period.

Use Cases

Because Compliance Enablement Preferences are defined by OU, the period of inactivity applies to the first job requisition OU to which the applicant applied. If the applicant is submitted by a recruiting agency or uploaded manually, then the period of inactivity also applies to the first job requisition OU to which the applicant applied.

Note: In some instances, a job seeker is not associated to an OU (for example: the person created a profile on a career site but did not apply to a requisition, or the person created a profile using 'Connect with us' but did not apply to a requisition). In this case, the settings defined at the top node will apply.

Connect With Us

For applicants who apply to the organization via Connect With Us, their applicant data is anonymized based on the settings for the Anonymize applicant data after a period of inactivity field so that their data does not stay in the system for an indefinite period of time.

Period of Inactivity Timer

The timer for the period of inactivity begins at the time the applicant is created, regardless of the source of the submission (manual, agency submission, applicant profile created by applicant).

The timer is reset each time the applicant logs in to their profile.

Once the period of inactivity is reached, the anonymized applicant data is scrambled. This ensures that an applicant's personal data is irretrievable following the period of inactivity.

Note: For applicants who are uploaded manually to a requisition, the period of inactivity is not reset if the applicant is active and manually re-uploaded.

Hired Status

Candidates in a Hired status are not anonymized. However, if the candidate is moved to a different status, then the period of inactivity timer restarts.

Require OFCCP Compliance Enablement Option

If the Require OFCCP Compliance Enablement functionality option is checked, then the Anonymize applicant data after a period of inactivity option is unchecked and disabled by default.

Number of Days to Notify Applicant Via Email Prior to Anonymizing

The Number of days to notify applicant option allows administrators to define when the Notify Applicant Prior to Anonymizing email is sent to applicants prior to anonymizing the applicant's profile data. This option is only enabled if the Anonymize applicant data option is checked.

To define the number of days, enter a number in the numeric text box, up to nine characters. The number entered must be less than the period of inactivity defined in the Anonymize applicants' data after field. If 0 is entered, the number is not recognized for triggering the email.

Once the applicant reaches the period of inactivity, as defined in the Anonymize applicants' data after field, the Notify Applicant Prior to Anonymizing email is sent to the applicant. Example: If the Anonymize applicants’ data after field is set to 6 months, the Number of days to notify applicant field is set to 14 days, then the email fires after 166 days of the applicant’s inactivity.

The email is fired each time an applicant reaches the period of inactivity. If the applicant logs into their profile on the career site prior to being anonymized, then the period of inactivity is reset. The email will fire again if the applicant reaches the period of inactivity again.

Note: The Notify Applicant Prior to Anonymizing email must be enabled by the administrator in Email Administration.

This option is unchecked by default. The Allow applicants to anonymize their profiles option enables administrators to allow external applicants to deactivate their own profile. When the option is selected, a Deactivate My Profile checkbox displays under the Edit Profile section on the My Profile page. Applicants can check the box to deactivate their profile. When the option is not selected, the Deactivate My Profile checkbox does not display.

Connect With Us

For applicants who apply to the organization via Connect With Us, their applicant data is anonymized based on the settings for the Allow applicants to anonymize their profiles field so that their data does not stay in the system for an indefinite period of time.

The ability to anonymize applicant data after a period of inactivity enables administrators to anonymize external applicants who have not accessed their career site My Profile page for a set number of days, and are not in an open status of a requisition. The clock to initiate the anonymization, starts clicking after the applicant’s last login date. Anonymizing an applicant means that the applicant's data will not be accessible by the applicant or Cornerstone. Neither the applicant's profile nor their resume will be searchable. If the applicant is in a New Submission status, their name will be replaced with "Anonymized" and their profile will not be accessible. Connect With Us users fall into the same bucket as external applicants.

This option is unchecked by default. To configure this option:

1. Under Tools > Recruit > Compliance Enablement, select the Anonymize applicant data after a period of inactivity option. This enables the period of inactivity to be defined.
2. Define the period of inactivity in the Anonymize applicant’s data after field. Enter the period of inactivity in the numeric text field, up to three numeric characters. This is a required field.
3. Select either "Days" or "Months" in the drop-down. If "Days" is selected, then the applicant is anonymized after the set number of days of inactivity. If "Months" is selected, then the applicant is anonymized after the set number of months of inactivity. Note: Inactivity is defined as the applicant not accessing their profile on the career site for the number of days or months defined in the Anonymized applicant’s data after field.

Because Compliance Enablement Preferences are defined by OU, the period of inactivity applies to the first job requisition OU to which the applicant applied. If the applicant is submitted by a recruiting agency or uploaded manually, then the period of inactivity also applies to the first job requisition OU to which the applicant applied.

Note: Former employees cannot self-anonymize from the career site. This covers use cases in which a former employee may have been added as an employee in another way, such as through a data load. The ability to self-anonymize is controlled by the Allow applicants to anonymize their own profiles option in Compliance Enablement Preferences; however, there is no preference that controls this specific former employee use case. Data deletion features based on retention period may still anonymize this data.

New Submission Data

Administrators can set personal applicant data as anonymous for new submissions. This reduces the chance of discrimination while reviewing new candidates. When the Anonymize personal applicant data for New Submissions option is selected, applicant data is made anonymous by not displaying new submission's name and instead replacing names with numbers. This setting is retroactive; thus, any new submission applicants, including existing new submission applicants, are made anonymous. After a new submission is approved, their name will display in the manage applicants page. If this option is unselected, all applicant data is no longer anonymous.

Note:

• If the Require OFCCP Compliance Enablement functionality option is selected, then this option is unselected and disabled.
• When the Skip New Submission Status option is checked in Requisition and Applicant Preferences, the Anonymize personal applicant data for New Submissions option is disabled and hidden. The option is hidden at the top level organizational unit (OU) and all child OUs.

Administrators can also allow external applicants to deactivate their own profile. If this is selected, logged in applicants can deactivate and anonymize their personal data by editing their profile. If an applicant anonymizes their profile, they will no longer be considered for any positions to which they have applied. The applicant will have to create a new profile in order to apply to any open position.

When an applicant anonymizes their own data, their profile will look as though the candidate has reached the period of inactivity for anonymization. No profile information will be searchable, and their profile will not be accessible.

Applicants can also request for their information to be anonymized. Clients can request a GTS work order to ad hoc anonymize applicant data. This will anonymize applicant data regardless of their period of inactivity or status. This will save the applicant from having to anonymize their own information via their profile.

Users in Scope

This functionality impacts external candidates who created a profile on a career site, those who applied as guest, those submitted by Recruiting Agencies as well as those who created a profile through Connect With Us.

Exclusions

If a candidate is in a Hired status, they will not be anonymized, regardless of their period of inactivity. The reason for this is because a recruiter may still want access to their resume. An open status is not limited to New Submission but is any status other than closed. If a candidate is in an open status when the requisition is closed and they are dispositioned, they will be anonymized after the designated time period.

In addition, regardless of a candidate’s period of inactivity, they will not be anonymized if they are in a Hired status. This is because there could be a latency between when a candidate is moved from hired to an internal employee. A recruiter would not want to lose their information during that time period. Data deletion for internal users is covered below in Data Deletion.

Additional Use Cases:

• If an applicant is in an open requisition, but has not logged in within the specified time period, they will still be anonymized.
• If an applicant becomes “Hired” their period of inactivity is no longer relevant. To anonymize a “Hired” applicant’s data their status will have to be changed to an inactive status.

Internal Users are hired employees whose candidate records have transformed to a user record. Clients can configure the period after which user profile data is anonymized, and their application information is deleted (time-based deletion) through the Legal Entity OU.

In the data deletion process for User Profiles, all application information is deleted while their name, email, and contact information is anonymized in the database. The scheme for core user data is based on the configuration defined for the user’s Legal Entity OU. A client can also request a one-off deletion of data for specific users (ad-hoc deletion). Data deletion is permanent and cannot be reversed.

An Internal User’s Data Deletion clock starts ticking once their status is changed to an inactive status (they are fired, quit, or request to be removed from the system).

The time-based application data deletion scheme impacts both internal and external applicants. The retention period is configured by the Location OU (the trigger is based on the primary location of a requisition). The trigger for the deletion is the first event happening: either the closing of the requisition or the disposition of the applicant when they are not hired. From this time, the clock starts ticking. When the retention period defined for the Location is reached, the application data is deleted.

For candidates in an active status in a Canceled requisition, candidate data is deleted based on the retention period and when the requisition was canceled. This will delete the applications only and not the user record. The candidates will still be searchable, but the applications will be deleted.

Applicant's inactivity does not matter for the deletion of their requisition data. In the case a client has anonymization AND Application data deletion configured, the applicant's profile can be anonymized and their application information will be deleted. It is possible, based on client configuration, that both events happen at different points in time.

Impacted Data

When either the application data deletion or user based data deletion event is triggered, all data for the user’s application is permanently deleted and will no longer be recoverable in the database. The following data will be deleted:

• Comments
• Ratings
• History / Audits
• Interviews
• Offer Letters
• Reviewers
• Selection Responses
• Realistic Job Preview
• Selection Assessment
• Skills Test
• Workflow Responses
• Competency Assessment Task
• Disclaimer
• EEO Question
• Training
• Custom Integrations
• Pre-Screening Responses
• Emails
• New Forms
• External Assessments
• Background Checks
• Attachments
• Flags
• Referrals / Costs
• Applicant Resume

When user based data deletion occurs, the above data points are deleted for ALL requisitions. In the case of only requisition data deletion occurs, the above data for only that specific requisition is deleted.

Implementation

This functionality is controlled by a backend setting that is disabled by default.

Request process: Global Customer Support work order submitted by client administrator in order to conduct the following:

1. Scheduled: One-time work order to define data deletion rules to Location OUs. Any new child locations would dynamically inherit the data retention rules for its parent’s.
   1. This should be identified across all Parent Location OUs
   2. Frequency (e.g., Monthly / Annual)
   3. Day / Date (e.g., 15th of the month)
   4. Specify Retention period (e.g., 12 months)
2. Applications - Day 1 of the retention period begins one day after the requisition is closed

The organization's named administrators who can submit a Global Customer Support work order will have the ability to make modifications to the data deletion configuration. It is the client’s responsibility to ensure the named administrators will adhere to the company data deletion policy and do not make modification without discussing with the client’s data security.

Click the Remove icon to remove the question from the OU.

This column displays the full text of the question. The following are the default compliance questions:

• Gender
• Race/Ethnicity
• Disability
• Veteran Status (VET-4212) - Note: Part 4212 option relates to disabled veterans, veterans of the Vietnam Era, recently separated veterans, other protected veterans, and armed forces service medal veterans. This question has the following response selections:
  • I identify with one or more of the categories of protected veteran described above
  • I am not a protected veteran
  • I choose not to self-identify
• Veteran Status (Part 60-250) - Note: Part 60-250 option relates to disabled veterans, veterans of the Vietnam Era, recently separated veterans, other protected veterans, and armed forces service medal veterans.
• Veteran Status (Part 60-300) - Note: Part 60-300 option relates to disabled veterans, recently separated veterans, active duty wartime or campaign badge veteran, and armed forces service medal veterans.
• Voluntary Self-Identification of Disability - When this question is added, the question always displays as the first question in the list and cannot be moved. If the Require OFCCP Compliance Enablement functionality option is checked, then the "Voluntary Self-Identification of Disability" question displays in the Compliance Questions section.

This column displays the question type, either Default or Custom.

This option is checked by default for default questions. This option is unchecked by default for custom questions. Check or uncheck the Required box to require or not require applicants to complete the question. Note: All questions in the Compliance Questions table appear in the Compliance Questions action item when the action item is included in the application workflow, regardless of whether or not the question is marked as required.

Click the Preview icon to view the question. This opens the Question Preview pop-up. The language, question text, and responses display. Both default and custom questions can be previewed.

For portals with multiple languages enabled, select the language in the Language field in which to display the question and responses.