As online recruiting has rapidly accelerated in the past decade, employers have grappled with whether they have to consider every single resume that comes in as an application, even if it wasn’t submitted for a specific job opening. Now the federal Equal Employment Opportunity Commission (EEOC) has released proposed new recordkeeping guidance clarifying who is a job applicant in the context of recruiting by Internet and related technologies (including e-mail, Internet resume banks, job boards, and employers’ own websites, resume databases, and online job listings).