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Like we said last month, data is the foundation and a necessity to all things AA compliance. And I am sure most of you would agree we have a love/hate relationship with our applicant tracking system (ATS). Managing all of your candidates electronically is so much easier then doing it manually, but there is a constant struggle between ease of use by the recruiter, simple process for the candidate and getting all the information required for compliance. Regardless of where you are on the spectrum, making the most of your ATS can ease your recordkeeping pain.

So how do you go about making the most of your ATS? By figuring out what you need, what you want and what you wish you could get out of your ATS. First let’s talk about what you need. It may sound simple but if you collect it, you must keep it and be able to get it out of your system.

What You Need
The first thing that should come to mind when you are thinking about what you need to gather in your ATS is the OFCCP’s Internet Applicant Recordkeeping Rule. Next would be the updated Section 503 & VEVRAA regulations as they relate to applicant data collection/recordkeeping and lastly would be the revised Scheduling Letter and Itemized Listing. Again, knowing what you need will give you the best idea on what to collect in your ATS.

This is a crucial step to complete even if you have an existing ATS that you set up within the past couple years. With the updates to the disabled and veteran regulations this year and the newly released scheduling letter and itemized listing, it is important to make sure you are keeping up with your collection and recordkeeping requirements.

What You Want
So you have figured out the items you need to collect and maintain for AA compliance, now think about what you want in your ATS. Now some of this is going to depend first on the capabilities of your ATS and second where you are at on the spectrum of ease of use vs. compliance. Let’s discuss the spectrum and how to figure out where you want to be. Here is a scenario to consider:

Does your company want to make it as easy as possible for the candidate to submit their interest? If you have an ATS that has very accurate parsing capabilities, then maybe completing just a few fields of information and attaching a resume may be your answer. That makes the candidate experience easy and doesn’t increase the workload of the recruiter by having to enter candidate information in the system manually. However, remember the third piece under consideration, AA data collection and recordkeeping. Do you add the request for race/ethnicity, gender, veteran and disabled status as part of the candidate’s original step during submission or do you require the recruiter to collect that information separately at a later date? Choose collecting it separately at a later date and you run the risk of a recordkeeping violation during an audit when it is discovered that the recruiters forgot to send the self-id form to everyone that met the definition of an internet applicant. So in the grand scheme of things maybe adding the self-id forms at the beginning of the process where they can be requested automatically of all candidates has a greater importance than the candidate experience.

Use that same thought process when analyzing your company’s candidate experience, recruiter needs and AA collection/recordkeeping requirements. There isn’t one right answer; I work with multiple industries and sizes of organizations and each have their own unique way of accommodating the needs of the business to make the process as simple as possible while maintaining their AA compliance needs. In case you were wondering, here are some of my “must haves” in an ATS:

  • Collection of race/ethnicity and gender information
  • Collection of veteran and disabled status (compliant with updated regulations)
  • Collection of application data
  • Detailed and/or custom disposition codes
  • Track the stage at which each candidate reaches
  • Track the source of each candidate
  • Restrict visibility of EEO information to selected individuals
  • Download all of this information into requested format (typically Excel)
  • Manual data purge only and delete functionality limited to selected individuals
  • Keep all history of applicant submission for each requisition, make sure it doesn’t update or overwrite information if applicant applies for multiple jobs
  • Standard and ad hoc reporting

What You Wish For
You have what you need and what you want out of your ATS, now it’s time to figure out what this baby can really do. What is it that you wish you could get out of your ATS? Think beyond AA compliance. Here are a few items on my wish list:

  • Integration with other systems (HRIS, Onboarding) – Let’s limit the amount of paperwork required to get an employee onboard and get these systems to talk to each other.
  • Report writing tool – I want the ability to pull any field of data in the system into a report for not only AA compliance but also for diversity, recruitment metrics, etc.
  • Multiple portals for all the ways you source candidates (internal, external, agency, etc.) – I don’t want to just manage external applicants, I want the same system for managing internal postings and those jobs that are sent out to agencies.
  • Multiple career pages for different types of jobs (professional vs. hourly or corporate vs. field) – The experience and information you share with candidates varies based on what type of job they apply for, having a custom experience for both enhances recruiting.
  • Multiple workflows for different types of jobs – I want to customize the steps I take a candidate through to be to the type of job it is.
  • Job posting at a click of a button – Make it easy for the recruiter to post jobs on job boards.

Final Note
This is by no means a complete treatise on setting up or choosing an ATS to be OFCCP compliant. It is meant to get you thinking about whether the system you have today is giving you what you need, what you want and what you wish for. No applicant tracking system can guarantee you OFCCP compliance; it is all in how you use the system. Even the best system with all the bells and whistles can still produce the worst data. Garbage in, garbage out. My best advice is know your OFCCP collection and recordkeeping responsibilities, know your system’s capabilities, use them to their fullest extent and train, train, train those who are going to use the system.



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