HRIS Considerations for Your Affirmative Action Program

You likely are not the owner of the Human Resources Information Systems (HRIS) for your company. However, being able to prepare, implement and monitor an effective Affirmative Action Plan relies on your ability to accurately gather and analyze personnel action data. Much of that information is stored in an HRIS. So, understanding how this is managed in your company is critical to the quality of your plans.

There are many HRIS systems available on the market that offer a wide variety of services and modules, including employee self-service, payroll, historical data retention, and reporting. Some systems are highly customizable and are compatible with other HR systems, such as an Applicant Tracking System (ATS). Most are cloud-based and require IT support, either internal or by the vendor. Regardless of the system used, there are some guiding principles to keep in mind:

1. Reporting features – Many systems come with “canned” reports that are set up by the vendor but that are not customizable. These might be adequate for some of the data you need for your plan development, but if regulations change, these might not provide the information that is needed. If possible, make sure that reports can be built or customized from your HRIS. Any custom reports should be saved, so that annual updates versus total rewrites can be made each year.
2. The GIGO Principle – The old computer science saying of “Garbage In, Garbage Out” holds true here. Reports coming from your HRIS are only as good as the data contained within it. For example, if information about employee work locations is not updated in your HRIS, the counts of employees in each location will not be reliable and could lead to having too many or too few Affirmative Action Plans. If you are not the person responsible for the data entry, make sure that you know who is and what protocols are followed. Partnering with those who do data entry to education about what you need and when you need it can assist in making sure that your data output is accurate.
3. System Changes – Being recognized as a stakeholder in what happens with the HRIS and its data is critical. If those making the decisions are unaware of your use of the data and the retention schedule regulations, changes in HRIS providers could render your data unavailable, unusable, or noncompliant. Make sure that any system changes or transfers will allow for easy access to all historical data. If provided with a “data dump” in lieu of data being transferred to a new system, make sure that it is easy to use and does not require an additional interface to read the data.
   *If possible, plan timing of any changes to not coincide with your annual reporting dates. Many companies look to make system changes in late December or January 1, but if you have an affirmative action program that runs on the calendar year, that could be problematic to prompt retrieval of your data at the start of your plan year.
4. System Updates/Upgrades – Similar to system changes, make sure that you are aware of any system updates and upgrades. Seemingly harmless changes, such as moving the location of the Voluntary Self-Identification of Disability form for employees in an employee self-service space can influence the quality of your data and perhaps even jeopardize compliance with regulations.
5. Other sources of data – While some companies choose to have all employee data stored in one system, other companies might use different systems for various processes. The most common example is HRIS and ATS systems are often 2 different systems that may (or may not) interact with each other. Be sure to consider all other sources of AAP data – such as an ATS, payroll system, performance management systems and succession planning systems when looking for all relevant data and understanding how it is entered into systems.

The OFCCP has specific frequently asked questions about electronic employment and personnel records. It is important to know what the agency has to say on this topic, but one area of note addresses basic characteristics of an electronic recordkeeping system (HRIS):

To satisfy the OFCCP requirements, contractors must ensure that their electronic recordkeeping system:

• Has reasonable controls to ensure the integrity, accuracy, authenticity, and reliability of the records kept in electronic format;
• Is capable of retaining, preserving, retrieving, and reproducing the electronic records;
• Is able to readily convert paper originals stored in electronic format back into legible and readable paper copies; and
• Has adequate records management practices in place.

These principles can be a good reference to when setting up or changing HRIS systems and should be shared with any internal team that is managing the HRIS for your company. More information about the OFCCP FAQs can be found here.

Having accurate and easily accessible electronic records from your HRIS is critical to good AAP preparation. Staying involved with the planning and maintenance of these systems in your organization will make your plans easier to create and implement and likely yield more accurate results.