internet outreach for diversity recruitment and ofccp compliance

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America’s Job Exchange 400 Minuteman Road, Andover, MA 01810 www.americasjobexchange.com American Association for Affirmative Action 2013 National Conference and Annual Meeting May 7-10, 2013 | San Antonio, TX Rathin Sinha President, America’s Job Exchange

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Page 1: Internet outreach for diversity recruitment and ofccp compliance

America’s Job Exchange400 Minuteman Road, Andover, MA 01810www.americasjobexchange.com

American Association for Affirmative Action2013 National Conference and Annual Meeting

May 7-10, 2013 | San Antonio, TX

Rathin SinhaPresident, America’s Job Exchange

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Disclaimer

Not legal advice. The presentation is intended only to stimulate discussions among practitioners and industry participants relating to affirmative action and OFCCP

compliance in internet recruitment and workforce development.

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We live in communities that are increasingly more diverse, including Veterans, individuals with Dis-ABILITY, Ethnicity, Race, Color, Gender, Age and more

Diversity in our Communities

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Proactively reach and attract candidates from these diverse communities for your job openings

Hire and retain these employees in an environment that free of discrimination by backgrounds

Ensure career growth and pursuit of excellence in an environment that provides equal opportunities

Diversity at the Workplace

Our workplace should resemble the diverse communities we represent

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Proactively leverage diversity and equal employment principles to make diversity a competitive advantage for your business

Step 2:Proactive Diversity

Develop and manage programs to ensure that both the letters and spirits of affirmative action and related laws are complied to

Step 1:Regulatory Compliance

The road to diversity excellence can be broken in two steps

Leveraging Diversity

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Represents the benefits of job seekers and employees• EO11246 – Equal Employment

• Section 503 - Americans with Disabilities

• VEVRAA/Section 4212 - Protected Veterans

Audits federal contractors and imposes corrective actions if deficient• Scheduling Letter, Information Request

• Desk Audits, On-Site Audits,

• Conciliation Agreement, Penalties, Debarment

The OFCCP enforces regulations relating equal employment & affirmative action in companies that do business with the Federal government

Role of OFCCP

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Executive Order 11246

Prohibits Federal contractors from discriminating in employment decisions based on race, color, religion, sex or national origin.

Section 503 of the Rehabilitation Act of 1973

Requires Federal contractors to take affirmative action to hire, retain and promote individuals with disabilities.

Vietnam Era Veteran’s Readjustment Act, as amended in conjunction with Jobs for Veterans Act (VEVRA/JVA)

Requires Federal contractors to take affirmative action to hire, retain and promote veterans.

It mandates that Federal contractors must comply with a set of regulations in their recruitment practices.

Key Regulations

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Increased Prominence• New leadership

• Budget increase

• Staff Increase

Heightened Enforcement • Higher incidents of audits

• Aggressive litigation

• Larger penalties

The OFCCP has been very engaged and active during the terms of the Obama administration

An Engaged OFCCP

Sources 1 Video speech at the National ILG Conference in Hawaii, 2012; http://www.dol.gov/ofccp/addresses/Director_address_NILG_Aug302012.htm

“Under the Obama administration, OFCCP compliance officers have reviewed more than 15,000 companies that do business with the U.S. Government. During that

period, we've recovered $38 million in back wages and more than 8,000 potential job

offers for nearly 80,000 workers...”

-Patricia Shiu, Director, OFCCP1

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Strengthening Regulations

It has also proposed new regulations and changes to current regulations

To improve employment opportunities for veterans and protected veterans

To improve employment opportunities for individuals with disabilities

To improve employment opportunities for women and minorities in the construction industries

To combat pay discrimination and develop new compensation data collection tool

To evaluate revisions to the guidelines on sex discrimination

To emphasize data collection, analysis , and data-driven review to track progress

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Requires Specific Recruitment Efforts• Must engage in certain number of outreach and recruitment programs

• Send job listings to the local employment service offices e.g. 1-stop centers

• Develop and maintain ongoing relationship with local Veterans Representatives

• Enter linkage agreement with listed organizations for recruitment and training

• Consult with Employer Resources Section of the National Resource Directory

Requires Enhanced Data Tracking• Initiate requests to have candidates self identify prior to job offer and collect data

• Track number of referrals from the state employment service delivery systems

• Track ratio of protected veteran referrals to total referrals & maintain data for 5 years

• Establish annual hiring benchmark and conduct annual review of recruitment efforts

Proposed Changes: Protected Veterans

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Requires Specific Recruitment Efforts• Must engage in a minimum number of outreach and recruitment programs

• Send job listings to the local employment One-Stop Career Center

• Maintain ongoing relationship with local State Vocational Rehabilitation Agency

• Enter linkage agreement with listed organizations for recruitment and training

• Consult with Employer Resources Section of the National Resource Directory

Requires Enhanced Data Tracking• Initiate requests to have candidates self identify prior to job offer and collect data

• Track number of referrals from the state employment service delivery systems

• Track ratio of disability referrals to total referrals & maintain data for 5 years

• Establish 7% as a hiring goal for this group and conduct annual review of progress

Proposed Changes: Individuals with Disabilities

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Mandatory Job Posting Outreach • Mandates specific methods of internet job postings and distribution

• Mandates additional outreach with community based organizations

Data Collection and Tracking• Pre-employment data collection for protected groups

• Effectiveness of recruitment efforts by source of candidates

Data Analytics• Analysis of candidate availability and actual hiring, compensation

• Annual review of recruitment efforts relative to goals and benchmarks

Proposed changes related to recruitment can be grouped in three areas:

Essence of Regulatory Changes

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Pace of Implementation

While pace of actual implementation has been relatively slow, it is expected to accelerate during the second term with continuity in purpose and leadership

Major focus to improve employment opportunities for the veterans and individuals with disabilities

Strict enforcement of compensation parity and possible development of compensation tool

Implementation of new scheduling letter with itemized information and expanded data tracking

Detailed adverse impact analysis, new compliance manual, focus on construction

Aggressive enforcement and audits with expanded coverage for first time contractors and SMB

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Changes in Systems and Processes

Career Site, ATS, HRIS, AAP/EEO-1/VETS-100 Submittals

Cost of Expanded Outreach

Direct cost and adminsitrative burden of job postings

Data Collection and Tracking

Collect, manage expanded set of data; protect for privacy

Complexity/Inconsistency of Enforcement

Individual interpretation of regulations

Federal contractors are already feeling the challenge of compliance related activities; -the proposed changes impose additional burdens

Impact on Contractors

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Automated TechnologyState-of-the-art web platform, job distribution technology,data exchange mechanism, and data tracking methodologies

Breadth of PartnershipsLarge network of partnerships with niche job sites, community organizations, states, associations and employment agencies.

Audit AssistanceExpertise and assistance on your side in the event of an audit including consultation, and retrieval and analysis of data

Brand DevelopmentEfficient and effective access to media, advertising, technology to attract, hire and retain a diverse set of candidates

Third party vendors such as AJE are increasingly considered as effective alternative to in-house only programs

The Role of Third Party Vendors

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Successor to America’s Job BankLaunched on the heels of termination of the AJB program of DOL

Destination for Job Seekers/Employers to ConnectSpecializes in the recruitment of diversity candidates and non-executive jobs

Specialists in online Diversity Recruitment and OFCCP ComplianceSpecializes in veterans and disability recruitment outreach and mandatory job listing online

AJE is a leading provider of recruitment advertising and compliance solutions

America’s Job Exchange

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Job listing is imported via an automatic feed for FTP, XML or direct scraping, or using online interactive posting

Job Posting as Outreach Media

Your Job

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The imported job is posted on the AJE national and state specific websites

Job Posting Outreach : Step 1

Your JobYour Job

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The job listing is then automatically posted on the AJE Mobile App.

Job Posting Outreach : Step 2

Your JobYour Job

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And then posted on the AJE Facebook App as part of Social Job Initiative

Job Posting Outreach : Step 3

Your JobYour Job

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The job opening is posted in the AJE network of Diversity Job Exchanges e.g. Veterans, Disability and much more.

Job Posting Outreach: Step 4

Your JobYour Job

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The job is included in relevant job alert emails sent to subscribed job seekers

Job Posting Outreach : Step5

Your JobYour Job

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The job opening is sent to aggregator sites to reach a broader audience

Indeed Simply Hired Glassdoor Juju Carrerjet TopUSAjobs Oodle

Job Posting Outreach : Step 6

Your JobYour Job

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It is then sent for distribution and posting to our partner sites e.g.

Veteran Job Boardswww.VeteranJobs.Net

www.Jofdav.com

www.allveteranjobs.com

Disability Job Boardswww.disabilityjobs.net

www.disabledperson.com

Diversity Job Boardswww.asianhires.com

www.africanamericanhires.com

www.alllgbtjobs.com

www.allhispanicjobs.com

www.diversityjobs.com

Job Posting Outreach : Step 7

Your JobYour Job

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The job posting is now sent to community based organizations (CBO) via emails Goodwill

Local chapters

Easter SealsLocal chapters

The ArcLocal chapters serving persons with intellectual disabilities

Department of RehabilitationLocal state offices

U.S. Department of Veterans Affairswww.va.gov

Job Posting Outreach : Step 8

Your JobYour Job

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It is then sent to the relevant state employment delivery systems e.g. 1-Stops, DVOPs, LVERs via emails.

Job Posting Outreach : Step 9

Your JobYour Job

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Finally the job posting is sent to the state job bank by direct feed or online posting

Job Posting Outreach : Step 10

Your JobYour Job

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Comprehensive 10 Step Outreach Program

Job OpeningYour

Job

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Making it Easy : Job Seeker User Experience

Outreach is step one – but making it easy for the job seekers to apply and get hired is key for a successful online diversity recruitment program

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Storage

Posting and distribution details saved for proof to auditors

Reporting

Easy to understand online reports – 24x7 access

Retrieval

Quick turnaround report retrieval going back 2-5 years

Analytics

Views and applies by source

Comprehensive and easy to use data analytics capabilities are key to measure effectiveness and drive continuous improvement

Data Analytics

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Job and Distribution Details

Create reports for the company as a whole or for specific locations or subsidiaries.

Reports can be saved and exported to PDF and Excel.

Detailed outreach and distribution information, including delivery method and date and time stamp.

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Individual Job Records

Links to job descriptions on AJE exchange sites along with links to outreach partner sites.

Individual job records provide the details on distribution to our network partners and the states.

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Individual Job Records

Links to emails and CSV files as evidence of distribution to community partners and state one-stop offices.

Jobs manually posted to the states include the state confirmation ID in your report.

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Account Dashboard

Job traffic results are available in total or by source for all of AJE’s traffic sources.

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Job Manager

Job posting history is easily accessible and up to date. Track your posting patterns to determine future needs.

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Batch Feed Monitor

Monitor batch feeds to manage performance and ensure your job imports are successfully received and processed.

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The AJE solution is used by hundreds of leading brands for diversity hiring and recruitment compliance

Total Solution from AJE

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Satisfied Customers

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For more information, please contact:

Thank You

Rathin [email protected]