Progressive organizations don’t view affirmative action plans solely as a federal requirement. They instead realize the great opportunity to go beyond OFCCP compliance and really make a positive impact on their organization. Read on to discover six ways in which you can join these organizations at the vanguard of advanced affirmative action practice.
As part of our ongoing program of panel webinars, we recently met to discuss ‘Advancing Affirmative Action Programs Beyond Compliance to Competitive Advantage’, with a trio of guests from organizations working beyond the basic OFCCP requirements. Our panelists, Bryan Glines (Manager, HR Compliance and Diversity at CenterPoint Energy), Edcar Johnson (People Analytics, BCBS/HCSC), and Lori Walker (VP, Senior Diversity & Inclusion Consultant at Comerica), shared some fantastic insights. This article dives into six of the best tips from the session.
1) Communication Is Key: Helping Rather Than Dictating
On top of their other skillsets, compliance professionals must concentrate on becoming skilled diplomats to other departments. It isn’t advisable to simply demand data from a talent acquisition or compensation team, or insist that they must take a certain action. This negotiation style risks sending the message that the needs of external forces (i.e. the OFCCP) outweigh those of the organization. You may get cooperation, but you may not get understanding or investment beyond what is compulsory.
Instead, always phrase your approach as a partnership. Yes, you need data and you need them to take action, but here’s how you will use it to help them, or this is why that action will be beneficial. Over time, you build a mutually beneficial relationship where a small investment of effort lets you help them significantly while addressing organizational D&I goals. You can introduce compliance concepts, and they don’t even have to be labeled as such. So long as the concept is useful to them, your usefulness to each other will continue to improve.
When you do deliver your findings, it’s important to explain their implications. Sit down with them, establish how you’re going to investigate the source of the issue. Create an action plan that helps point out your concerns if the problem doesn’t simply go away. Over time, you should build in a very disciplined approach: establish a cadence of visits, so your teams know when they can expect you and schedule time and resources accordingly.
2) Use Your AAP Data for as Many Processes as Possible
Instead of thinking about ‘affirmative action data’, it’s healthier from a team-wide collaboration perspective to think about the ways data can be used beyond AAPs. You could meet with leaders once a quarter and strategically identify (from a D&I standpoint) what you can do with the data to help drive initiatives in the organization.
Going forward, the data can reveal what has been successful and what hasn’t been— you can use it to define sourcing strategies that would address certain needs and to ensure whether employees are given opportunities across the board. Be conscious of other factors, such as regional differences, that the data reveals.
More from the blog: ‘3 Reasons to Monitor Your Affirmative Action Plan (And 3 Ways to Do It Well)’
3) Being Selective for the Sake of Your Partnership
In large organizations with thousands of workers, the sheer amount of data to work with forces you to be selective, even when working on the recommended quarterly basis. Rather than overwhelm your partners, it’s best to go through and flag only those issues that are the most statistically significant—three standard deviation levels or higher—for discussion.
These are naturally the areas that are most likely to have actionable changes and the biggest positive impact. It’s still important to keep an eye on those less statistically significant areas, but don’t overwhelm your partners by flagging them until it’s necessary to do so.
4) The Importance of Getting Your Data Ducks in a Row
As far as possible, you want to ensure that you are documenting your processes (hiring, applicant pool, promotion, etc.) and following those processes consistently. Unfortunately, this is complicated in most organizations by the fact that data is often drawn from different sources.
A few lucky organizations may pass data from a recruiting management system to an employee system from the same platform provider, with the same fields. However, in a world of mergers and subsidiaries and a multitude of factors that inform platform selection, an organization may well be doubling up on certain systems and approaches. Add the different employees entering and moving data between these systems, and it’s a recipe for a disorderly dataset.
Once again, the key is to work with your partners to overcome this obstacle. To not just tell them “you need to sort this out for us”, but to explain exactly what you need, why you need it, and establish a realistic and fair idea of when you need it by.
Establishing consistency, processes and best practices is essential for making your own data cleaning effort easier, allowing you to get to your analysis quicker. You’ll need to look out for things like individuals having duplicate promotions, missing terminations, or people in incorrect job titles.
Read more: ‘Leveraging your AAP for Better Workforce Insights’
5) Creating More Space to Be Heard by Leadership
One of your leadership’s biggest challenges is the sheer volume of employment decisions they face. This inevitably puts a strain on the amount of time those leaders actually have to spend on any issues that arise, placing limitations on compliance professionals’ ability to discuss and flag issues (and obtain buy-in for their solutions).
One way of creating more airtime is by going to other stakeholders. When these third parties independently go to the leadership, invested in the issues you have highlighted to them, they may bring you along—or they will at least bring your material along to talk through.
As with all groups in your organization, a big factor in getting the buy-in you need is how you present any issue. Leaders are generally more receptive when you discuss compliance programs as a smart way of managing people overheads and talent. It’s a lot easier to embed it into their strategy when coming at it from that angle, rather than as a compliance issue.
You might also like: ‘Ask an Expert: New Voluntary Self-Identification of Disability Form’
6) Don’t Neglect Your External Partnerships Either
Leader and stakeholder relationships are the key to unlocking organizational change but don’t forget the power of an outsider perspective and external expertise. The majority of diversity and inclusion issues aren’t intentional, a fact that makes unpicking them difficult through self-reflection alone. External specialists such as Affirmity are aware of the latest compliance requirements and have plenty of experience in other (often comparable) organizations to draw upon.
A robust Affirmative Action Program software solution is also a significant tool for having efficient, impactful conversations. Alongside your own investigations into the raw data, interactive dashboards like those in Affirmity’s offering, provide an easy-to-use and uncomplicated summary view. These can be shared with executives, line managers and HR leaders to promote wider understanding, and help them satisfy their curiosity about progress against goals as often (or as infrequently) as they want.