Run internal audit to uncover hiring bias

It’s entirely possible for employment discrimination to fly under HR’s radar. All it takes is too much trust that hiring managers wouldn’t knowingly violate your anti-discrimination policies. That’s why it’s critical to regularly audit your organization’s hiring practices.

Advice: Periodically pull out all your job applications. Analyze who received job offers and who actually accepted employment. As much as possible, look for patterns that might reveal hidden hiring bias. Were women or older applicants disproportionately rejected for jobs they could have performed?

You might be surprised at what you find. Such hidden bias often occurs with entry-level or lower skill jobs, where there isn’t a lot of upper management involvement in the hiring process. It can be a costly problem.

A recently settled EEOC lawsuit illustrates the peril. The employer, Zoo Printing in Kentucky has agreed to pay over $625,000 to women who applied for jobs as box fillers and packers. Sharing the settlement fund will be women who, over the course of two years, met the minimum requirements for the job but weren’t hired. Apparently, no one in management realized women were being systematically turned down.

Follow these steps to avoid hidden bias claims:

• Establish a system for collecting all completed applications. Hiring managers must forward every application to HR.
• For each category of jobs, conduct an internal audit. First, determine which applications on their face show the applicant meets the minimum requirements for each filled position.
• Determine protected characteristics (refer to your EEO-1 form).
• Compare protected characteristics of those hired with those not hired. If you discover significant differences, investigate further. Ask hiring managers to explain discrepancies.
• Fix the problem by insisting on hiring qualified candidates across protected characteristics.