Successfully passing the Compliance audit is only the beginning.
According to the Employment Equity Act and Regulations, all organizations under the Federal Contractors Program (FCP) are required to make efforts to ensure the success of their Employment Equity program. The ongoing FCP requirements are specified in these key areas:
Employment Matters offers Ongoing employment equity Compliance Services, to help clients retain their Federal Contractor status.
Requirement #1: Communications
Communication of all aspects of Employment Equity (EE) is required by the Employment Equity Act and is essential to the success of the organization’s EE Program. The organization must continue on a regular basis to communicate and provide updates on:
- The purpose of EE and the organization’s commitment towards the implementation of Employment Equity and updates on progress achieved to date.
- All Employment Equity-related policies such as: Accommodation Policy, Anti-harassment Policy, Employment Equity Policy.
- Contact information for the Senior Official/EE Contact, if any change.
- Employment Equity information and any recent communications to all new employees. This can be included in an Orientation Package.
- Major changes to the organization’s structure.
- Recent activities or changes to the Employment Equity Committee or consultations with union and/or employee representatives.
- Regular communication of Employment Equity goals to managers responsible for their implementation to ensure representation is being achieved - once per year at a minimum.
Requirement #2: Employee Equity Data
The Employment Equity Act and Regulations require organizations to revise data when the following occurs:
Workforce Survey
- Provide new employees with the self-identification questionnaire.
- Adjust survey results to reflect any new hires, promotions or terminations.
- Adjust survey results when employees wish to change any previously submitted information.
Internal Workforce Data System
- Track all hires, promotions and terminations in order to achieve at least three years of Employment Equity data for the follow-up compliance review.
- Ensure that the most recent internal workforce data made available through the survey results are entered on a regular basis into either HRSDC’s Employment Equity Computerized Reporting System (EECRS) or a Human Resources Information System.
Workforce Analysis
- Incorporate most recent Census data when made available.
- Track changes in geographical recruitment areas or new occupational groups or changes to the composition of existing ones.
- Track new hires, promotions, terminations and survey results.
- Ensure any new gaps identified are addressed in the Employment Systems Review accordingly.
Requirement #3: Monitoring
Under the Employment Equity Act and Regulations, an organization is required to monitor, on a regular basis, progress towards Employment Equity in the following manner:
- Maintain Employment Equity Plan and all related elements up-to-date.
- Review effectiveness of the Employment Equity Plan at least once every three years or as a result of changing circumstances and determine if reasonable progress is being made.
- Make any revisions required to short-term hiring goals and other elements of the Employment Equity Plan at least once every three years or as a result of changing circumstances.
- Implement positive policies and practices as a result of the Employment Systems Review and record results to demonstrate reasonable effort if goals are not achieved.
- Review new policies and practices to ensure they do not constitute a barrier.
- Update data in survey results, workforce analysis and the employment systems review accordingly.
- Review degree of under-representation or gaps for each designated group in each EEOG.
- Review results of clustering and flow data analysis.
- Ensure guidelines are in place for employees who need to request accommodation and managers/supervisors who need to provide accommodation.
- Implement corrective or special measures as a result of the Employment Equity Plan.
Requirement #4: Record Keeping
Under the Employment Equity Act and Regulations, an organization is required to maintain the following records until completion of the next review:
- Communication activities provided to employees regarding Employment Equity.
- Consultation and/or Employment Equity Committee activities.
- Copies of blank self-identification questionnaires and all related documentation (e.g. cover letters, FAQs, closing date of survey, return and response rates).
- Workforce Analysis Summary Report.
- Employment Equity data records of each employee’s designated group membership, status (full time, etc), location, occupational group, salary and salary increases, hiring, promotion and termination kept in a separate location from personnel files.
- Copy of databases/computer records from present compliance review.
- Description of recommendations, activities undertaken and results of the employment systems review.
- Copy of the Employment Equity Plan.
- Record of organization’s monitoring of the implementation of the Employment Equity Plan.
- Location of Employment Equity data storage; who has access to hard and electronic copies, which electronic system is used to store and produce reports of Employment Equity data.
|
