Just as in cooking, an Affirmative Action Program (AAP) is only as good as each of its ingredients. The most important ingredient in a successful AAP is good data. Federal contractors would be wise to spend more time understanding this ingredient before they begin mixing in others.

Simply put, any analyses of a federal contractor’s personnel activities or progress in meeting placement goals is only as good as the initial data that is used to create the analyses. This is particularly true in light of the Office of Federal Contract Compliance Programs’ (OFCCP) practice of “following the numbers” in compliance reviews—an approach which focuses on all statistically significant adverse impact findings, regardless of who the protected group is. All too often, however, federal contractors of all sizes struggle with managing the vast amounts of hiring and personnel data they gather each year.

Contractors should consider the following tips to improve data management:

• Contractors should review all AAP data requirements with their data systems team. For example, when preparing an annual AAP, do you gather applicant data for all individuals who applied during the one year period, or only those individuals who applied to positions for which there was a hire during the one year period? Since you are analyzing selection activity, a good practice is to “reverse engineer” your applicant data—meaning you first identify all relevant selection decisions and then develop the applicant pools for each decision. Least helpful, and likely to cause problems, is the use of a “data dump” for this AAP ingredient.


• Start at the beginning, and review EEO-1 job categories, AAP plan coding, and job group structure records. Because these data elements are often revised infrequently, over time these records do not reflect the current reality of your workplace. When reviewing job groups, contractors should remember there is no particular size requirement for job groups—even a job group of one is permitted!


• Contractors should review their applicant tracking processes annually to be sure they are maintaining data by requisition when possible, and detailed disposition information. This includes information regarding the “step” (the stage of the hiring process where the candidate was rejected, such as résumé review, phone screen, or manager interview) and “status” (the reason the candidate was rejected).


• Contractors also should audit their data management and recordkeeping practices proactively—before an OFCCP compliance review is scheduled. All too often, data problems go unnoticed until OFCCP begins asking detailed questions about a contractor’s personnel activities data.

Though just one part of a compliant AAP, effective data management is vital to its overall success.

To learn more about the importance of data management in your AAP, contact a Berkshire compliance expert at 800.882.8904.