For federal contractors subject to the jurisdiction of the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP), the company’s human resources management system (HRMS) and applicant tracking system (ATS) normally are the two primary repositories of information critical to meeting the company’s equal employment opportunity and affirmative action (EEO/AA) obligations. Rarely designed with EEO/AA compliance requirements in mind, however, these systems often need to be heavily modified and “customized” to meet these needs.
As a result, if and when the business decision is made to change HRMS and/or ATS software platforms, EEO/AA compliance professionals need to be involved to ensure not only that necessary data is preserved in accordance with OFCCP recordkeeping requirements, but that “legacy” information remains meaningfully accessible for either ongoing or potential future compliance audits.
In order to assist employers that may be undergoing such a change, NT Lakis staff has prepared a general guide to system transitions. Employers should note that specific circumstances will vary in any such transition project; therefore, this guide is not intended to provide legal advice.
Members of the Equal Employment Advisory Council (EEAC) can read more here.