You just spent time compiling, analyzing, and reviewing data for your Affirmative Action Plan (AAP). Your company also wants to report on broader diversity metrics – can you use your work in the AAP to fulfill the request?

Diversity in the workplace means having employees who come from varied backgrounds – this might include any number of areas, such as race, gender, ethnicity, age, sexual orientation and religion. But it also extends to other areas such as education, abilities, and socioeconomic status.

Companies may have different reasons for focusing on diversity in the workplace, but often it includes meeting business objectives, culture shifting, bringing in different perspectives, and economic benefits. When companies have a commitment to emphasize diversity among their workforce, they may look for metrics to help track and meet initiatives.

The data that is collected and analyzed for an AAP is based on regulations and is specific to gender, race/ethnicity, disability status, and protected veteran status. Employees are grouped together by locations and job functions. There are specific requirements for how to analyze the data and for sharing and implementation of results. This can make the AAP data a good place to start for broader diversity metrics because it saves time and resources by utilizing data that is already available. Additionally, a consistent message can be reported by a company when the data comes from a single source, rather than AAP data versus general diversity numbers. Outreach efforts engaged in based on AAP results can also help a company in other diversity initiatives, so again there can be synergies when the two efforts work together.

“It is recommended that companies consult with legal counsel before deciding to request data from employees that they are not required to collect.”

However, there are some drawbacks to using AAP data for diversity metrics. As mentioned, the data for AAPs are very specific and may not easily translate to the desired diversity metrics. Companies don’t typically collect data that they are not legally required to, so being able to measure items outside of the AAP data points would be difficult. It is recommended that companies consult with legal counsel before deciding to request data from employees that they are not required to collect.

Other limitations to AAP data are that it may only cover a portion of a company’s workforce. For global companies, employees outside of the United States may not have been included in the data analysis. AAP data also segments employees by locations and job functions. For the purposes of diversity metrics, companies may want to look at different groupings of employees.

Overall, when deciding to use AAP data for broader diversity metrics consider the following:

Data Collection  How often will the data be collected? What metrics will be included? What employees will be included?

Data Analysis  How will the data be analyzed? How will employees be grouped?

Ownership Who owns the process and programs? How will these groups work together? What will be done with the information? Who will receive results? What actions will be taken as a result of the analysis?

Regardless of if a company uses AAP data for other company initiatives such as broader diversity metrics, it is important to remember that any obligations a company has as a federal contractor should continue to be met and not altered or abandoned as a result of these initiatives.

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