Data is the foundation and a necessity to all things AA compliance. It can be something you get easily or it can become the bane of your AA existence. What is the difference between getting that data easily and it becoming a struggle? Technology. Now I don’t mean you have to have cutting edge systems with all the bells and whistles, but you must understand the capabilities of the systems you do have and create processes for the rest. So let’s start with the two big systems most companies have, HRIS/HRMS and ATS: Human Resources Information Systems/Human Resources Management Systems and Applicant Tracking Systems. These two systems hold data for all your potential, current and past employees. This article will focus on the data in your HRIS/HRMS, and the next installment will focus on your ATS data.

What information does your HRIS/HRMS store?

THE BASICS
It can be as basic as your employees’ most recent information including name, race, gender, veteran status, disabled status, title, hire date, termination date, department and pay. This is typical information contained in a payroll only based system. Historical information such as previous pay, titles, etc. is not stored. When this is the state of your HRIS, it is important to have in place manual systems to collect historical data for your promotion, termination and hire activity. This usually means keeping up an Excel spreadsheet that contains each employment activity for the plan year.

It is also important to pull reports from your system as close to the effective date of your AAP as possible in order to pull the most accurate data. As your organization grows, collecting all the data needed will become time consuming. Keeping up with entering the data both in your HRIS and the spreadsheet in real time will help spread out the work and not take so much time when you update your AAP.

GIVES ME WHAT I NEED
I can get what I need: current and past employee information along with all employee transactions. If this is the state of your HRIS, collecting the basic data needed for your AAP is not as daunting or manual of a task. But there still may be items that are stored outside the system in order to create your AAP. These may include EEO codes, census codes and AA job groups. Typically an Excel spreadsheet is created in which these extra codes are assigned by job title and that table is uploaded into your AAP software or used as a reference table when completing your AAP. It may be worth finding out from your HRIS vendor if these are fields that can be added to the job table in your HRIS system so you have one less step to complete your AAP. Also if you are in the midst of an upgrade or looking at options for a new HRIS, keep these fields in mind and read below for some additional fields and functionality.

HOLDS IT ALL
So all of the data you need to create your AAP comes straight out of your HRIS/HRMS without the need to maintain external tables. This is where the fun begins. Getting the data for your AAP is easy; now start thinking about the extras that will make drilling down into your data easier to do. Think about how much easier compensation analysis would be if you could pull straight from your system not only the time in current job, but time in previous job and outside experience before starting with your company. Also think about what impacts pay for your jobs. Is it education? Is it certifications? Is it experience? Well those are all regression factors you would use to explain differences in pay. Why not have that information at your fingertips in your HRIS/HRMS?

Staying on the compensation topic, the OFCCP proposed a rule wanting to collect W-2 data and total hours worked in an EEO-1 format. For a lot of companies that would require pulling data from multiple systems, so is it possible with your current system to pull the data you would need? Let’s also not forget that the AAP is not the end of the road. If your organization also has a Diversity Plan it may require you run the data a little differently than you do for your AAP. It may be location based for your AAP, but you break down data by division or function for diversity purposes.

Lastly, when you have maximized your HRIS/HRMS, it may be time to talk integration with other systems: Performance Management, Applicant Tracking System, Onboarding and Payroll/Time & Attendance. All of these systems may have data that is important to your AAP, next audit or deeper dive into your data. Your HRIS/HRMS would be a better friend if it had it all and played nice with others.

At this point, it may feel like I have asked more questions than I have answered. That was the point: to get you thinking about what your system is capable of today, find out what your system is capable of tomorrow and, for the gaps, make sure you are creating a work around that works for your organization. Think about turning your HRIS/HRMS from a foe to a friend by asking these questions, finding out the answers and making the most out of your system.

To make up for all the questions, here are a few general tips about your AAP data:

• Good data in, accurate reports out. Bad data in, unreliable reports out. Keeping the data clean and up to date is important to accurately set your goals and analyze your employment activity.


• Getting accurate data starts with good data, but you must also know what is behind all the reports you are pulling. Find out what category of employees it is pulling. Find out if the hire log is pulling the job title as of the date of hire or current job title. This is important if someone has been promoted since being hired. How is the promo log programmed to pull? Does it match your organization’s definition of a promotion?


• A lot of the questions you have about your AAP, other people have asked the same thing. So going to the OFCCP’s website and reviewing the FAQs can be very helpful. Here are a few that impact the type of data you have in your HRIS/HRMS and AAP.
  • Electronic Recordkeeping Systems: http://www.dol.gov/ofccp/regs/compliance/faqs/dir279faqs.htm
  • Employer-Employee Relationship (who goes in your plan): http://www.dol.gov/ofccp/regs/compliance/faqs/Employer-Employee_Relationship.html
  • Compensation Guidance: http://www.dol.gov/ofccp/regs/compliance/faqs/CompGuidance_faq.htm

Final thought: While we AA folks may be the ones pulling the data, analyzing the data and creating the AAP, we don’t maintain the data, program the reports or manage the system. So make friends with your HRIS department and make sure they understand your needs and train your HR partners on the impact of entering data into the system so you get the cleanest data.