TM - June 2008 - (Page 22) recruitment & retention assessment & evaluation compensation & benefits performance management learning & development succession planning Carefully Evaluate 10 Key F actors Because the OFCCP has begun thoroughly investigating federal contractors’ practices to eradicate systemic discrimination, it is imperative organizations prepare appropriately. HR and talent management leaders are obligated to regularly develop, analyze and review affirmative action plans to make sure they’re in accordance with current regulations. If irregularities are found, companies must proactively amend their recruitment practices. Rather than wait until the OFCCP sends a scheduling letter to begin audit preparations, organizations should be prepared. Federal contractors should analyze 10 factors to improve compliance with OFCCP regulations: will ensure an adverse impact analysis can be accurately performed. 7. Review tests or questionnaires. Tests must be applicable to the job requirements in order to be considered valid. A test that is not relevant for a position should not be required, as it could disproportionately exclude certain demographic groups from consideration as candidates. 8. Did managers interview people not in the ATS? By identifying interviewees not in the company’s ATS, companies can determine additional methods by which applicants are being received. Policies should be implemented to account for these individuals. 9. Assess record-retention policy interview notes. Federal contractors must maintain recruitment records for up to two years from the position’s date of hire. Records must be kept for this time period to guarantee all data is available for review in the event of an OFCCP audit. 10. Examine third-party recruitment vendors. Companies using third-party vendors cannot pass liability for noncompliance to the vendor. So if utilizing a third-party search firm, the company must be certain the vendor operates in compliance with OFCCP regulations. Act Now to Change aulty Practices F In the past, the OFCCP often conducted drive-by audits by simply evaluating a company’s affirmative action plan and narrative. But those days are gone. In recent years, the OFCCP adopted a new approach that moved away from individual or isolated discrimination cases and shifted toward analyzing patterns indicating company-wide systemic discrimination. In doing so, the OFCCP has more than doubled the back-pay settlements spurred by evidence of systemic discrimination. Companies are finding the OFCCP is much more strategic in its approach to systemic discrimination. If the OFCCP finds signs of significant systemic discrimination within a company, the agency will even put other scheduled audits on hold to look for similar signs in the company’s open audits. By evaluating recruitment practices from beginning to end, the OFCCP can pinpoint areas in which adverse impact occurred repeatedly. The consequences of systemic hiring discrimination can damage a company from several different angles, all of which have enduring impacts. Rather than discovering noncompliance penalties firsthand, federal contractors must update their hiring practices to coincide with OFCCP regulations. As recruitment compliance evolves, recruitment processes should, too. Don’t wait until it’s too late. Kurt Ronn is the president and founder of HRworks, a national recruitment firm that helps major companies acquire talent to build their organizations. He can be reached at editor@ talentmgt.com. The OFCCP indicates that in 30 percent of its audits, recordkeeping violations are uncovered. 1. Evaluate the organization’s applicant tracking system (ATS). Using updated recordkeeping technology can significantly mitigate the risks associated with noncompliance. 2. Select a random sample of positions across multiple divisions/functions. By sampling a random group of positions, compliance can be evaluated across the entire organization. Rather than focus on a specific department, a broad sampling likely will reveal company-wide shortcomings. 3. Follow the process from job posting to hire. Systemic discrimination can occur at any point in the hiring process. Therefore, positions should be evaluated from posting to hire to determine if there are any insufficiencies. 4. Basic qualifications should be clear and documented. Basic qualifications determine who is or isn’t considered to be a candidate for a position. Qualifications must be clearly articulated and documented to ensure all eligible candidates are fairly considered. 5. Document resume-database searches. Database searches must accurately reflect the basic qualifications listed for the position, so recruiters must pay special attention to keywords used. Searches must not go beyond the basic qualification criteria, or some candidates may inadvertently become applicants. 6. Analyze race, ethnicity and sex data-collection procedures. When a person becomes an applicant for a position, voluntary race, ethnicity and sex information must be requested and recorded. This 22 June 2008 talent management magazine www.talentmgt.com http://www.talentmgt.com
Table of Contents Feed for the Digital Edition of TM - June 2008 TM - June 2008 Editor’s Letter Contents Human Performance Leading Edge Foundations The New Components of Compliance Candid Culture: Embracing Employee Complaints Transitioning to a New Era: C&B at Nonprofits Three Ways to Build Successful Manager-Employee Relationships Implementing Successful Learning Programs The Succession Fix Fifth Third Bank: Putting People First Zaxby’s: Making Employees’ Jobs as Palatable as Its Menu Workforce Readiness: Preparing Personnel to Meet Business Goals Kelley Blue Book: Writing the Book on Performance Management Advertisers’ Index Editorial Resources Full Potential TM - June 2008 TM - June 2008 - (Page Intro) TM - June 2008 - TM - June 2008 (Page Cover1) TM - June 2008 - TM - June 2008 (Page Cover2) TM - June 2008 - TM - June 2008 (Page 3) TM - June 2008 - Editor’s Letter (Page 4) TM - June 2008 - Editor’s Letter (Page 5) TM - June 2008 - Editor’s Letter (Page 6) TM - June 2008 - Editor’s Letter (Page 7) TM - June 2008 - Editor’s Letter (Page 8) TM - June 2008 - Contents (Page 9) TM - June 2008 - Contents (Page 10) TM - June 2008 - Contents (Page 11) TM - June 2008 - Human Performance (Page 12) TM - June 2008 - Human Performance (Page 13) TM - June 2008 - Leading Edge (Page 14) TM - June 2008 - Leading Edge (Page 15) TM - June 2008 - Foundations (Page 16) TM - June 2008 - Foundations (Page 17) TM - June 2008 - The New Components of Compliance (Page 18) TM - June 2008 - The New Components of Compliance (Page 19) TM - June 2008 - The New Components of Compliance (Page 20) TM - June 2008 - The New Components of Compliance (Page 21) TM - June 2008 - The New Components of Compliance (Page 22) TM - June 2008 - The New Components of Compliance (Page 23) TM - June 2008 - Candid Culture: Embracing Employee Complaints (Page 24) TM - June 2008 - Candid Culture: Embracing Employee Complaints (Page 25) TM - June 2008 - Candid Culture: Embracing Employee Complaints (Page 26) TM - June 2008 - Candid Culture: Embracing Employee Complaints (Page 27) TM - June 2008 - Candid Culture: Embracing Employee Complaints (Page 28) TM - June 2008 - Candid Culture: Embracing Employee Complaints (Page 29) TM - June 2008 - Transitioning to a New Era: C&B at Nonprofits (Page 30) TM - June 2008 - Transitioning to a New Era: C&B at Nonprofits (Page 31) TM - June 2008 - Transitioning to a New Era: C&B at Nonprofits (Page 32) TM - June 2008 - Transitioning to a New Era: C&B at Nonprofits (Page 33) TM - June 2008 - Transitioning to a New Era: C&B at Nonprofits (Page 34) TM - June 2008 - Transitioning to a New Era: C&B at Nonprofits (Page 35) TM - June 2008 - Three Ways to Build Successful Manager-Employee Relationships (Page 36) TM - June 2008 - Three Ways to Build Successful Manager-Employee Relationships (Page 37) TM - June 2008 - Three Ways to Build Successful Manager-Employee Relationships (Page 38) TM - June 2008 - Three Ways to Build Successful Manager-Employee Relationships (Page 39) TM - June 2008 - Implementing Successful Learning Programs (Page 40) TM - June 2008 - Implementing Successful Learning Programs (Page 41) TM - June 2008 - The Succession Fix (Page 42) TM - June 2008 - The Succession Fix (Page 43) TM - June 2008 - The Succession Fix (Page 44) TM - June 2008 - The Succession Fix (Page 45) TM - June 2008 - The Succession Fix (Page 46) TM - June 2008 - The Succession Fix (Page 47) TM - June 2008 - The Succession Fix (Page 48) TM - June 2008 - The Succession Fix (Page 49) TM - June 2008 - Fifth Third Bank: Putting People First (Page 50) TM - June 2008 - Fifth Third Bank: Putting People First (Page 51) TM - June 2008 - Zaxby’s: Making Employees’ Jobs as Palatable as Its Menu (Page 52) TM - June 2008 - Zaxby’s: Making Employees’ Jobs as Palatable as Its Menu (Page 53) TM - June 2008 - Zaxby’s: Making Employees’ Jobs as Palatable as Its Menu (Page 54) TM - June 2008 - Zaxby’s: Making Employees’ Jobs as Palatable as Its Menu (Page 55) TM - June 2008 - Workforce Readiness: Preparing Personnel to Meet Business Goals (Page 56) TM - June 2008 - Workforce Readiness: Preparing Personnel to Meet Business Goals (Page 57) TM - June 2008 - Workforce Readiness: Preparing Personnel to Meet Business Goals (Page 58) TM - June 2008 - Workforce Readiness: Preparing Personnel to Meet Business Goals (Page 59) TM - June 2008 - Kelley Blue Book: Writing the Book on Performance Management (Page 60) TM - June 2008 - Kelley Blue Book: Writing the Book on Performance Management (Page 61) TM - June 2008 - Kelley Blue Book: Writing the Book on Performance Management (Page 62) TM - June 2008 - Kelley Blue Book: Writing the Book on Performance Management (Page 63) TM - June 2008 - Kelley Blue Book: Writing the Book on Performance Management (Page 64) TM - June 2008 - Editorial Resources (Page 65) TM - June 2008 - Full Potential (Page 66) TM - June 2008 - Full Potential (Page Cover3) TM - June 2008 - Full Potential (Page Cover4)
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