Pay Transparency-HRIS systems

[Susie Costa]

#97401

Forum: Community

Hello, me again!

In reading the information provided, it indicates that we should have an HRIS that can handle required disclosures and analytics. Is this part of the new legislation?

Also, currently we do conduct regular cadence in conducting fair pay analysis to address gaps. Does this have to be documented and kept? If so, for how long?

Lastly, do we have any reporting obligations?

Thank you!
Susie

[Haley O’Halloran]

#97404

Good questions. Here’s how the Pay Transparency Act treats your issues — and some practical considerations for your organization (a non-profit with fewer than the large-employer thresholds at present).

1. Does the legislation require an HRIS or analytic system?

No, the Act does not explicitly require the employer to have a dedicated HRIS (Human Resources Information System) or analytics tool. The legislation mandates certain data-collection, disclosure and reporting obligations, but does not prescribe the exact technology or system you must use.

More detail:

Under the Act and the associated Regulation, “reporting employers” must collect prescribed employee information (gender category, pay, hours, overtime, bonus, etc.) in order to prepare the annual “Pay Transparency Report”.

The guidance notes that employers should “collect and process pay rate information and identify differences in the prescribed gender categories.” (The Government of B.C. has also developed a Pay Transparency Reporting Tool (PTRT) to assist employers.)

Because these obligations involve data collection, aggregation and reporting, many employers have chosen to use HRIS or analytics-capable systems as a practical matter — but this is a choice or a best-practice rather than a legal hardware requirement.

Since you already conduct regular fair-pay analyses and likely have HR/payroll data, you’re well positioned. From a compliance/risk-mitigation perspective it is wise to ensure your systems can:

-Capture the required data (gender category, pay, hours, bonus, overtime) in a way consistent with the Regulation.
-Provide the ability to generate or extract reports for potential future “reporting employer” status.
-Ensure secure handling of personal/identity data (voluntary disclosures of gender, etc.), aligning with privacy obligations.

So while the law doesn’t force you to buy a specific HRIS, using one (or ensuring your current system supports these functions) is prudent.

2. Must your fair-pay analysis be documented and retained? For how long?

Yes, any analysis you conduct should be documented (i.e., you should keep records) — both as a good governance practice and to support compliance (and if you become a “reporting employer”).

There is no specific retention period in the Pay Transparency Act that covers “how long you must keep the analysis/reporting work-papers” for the pay transparency regime. However:

Under the Employment Standards Act, employers must keep payroll records for 4 years after the record is created. Given that the pay transparency regime draws on payroll/pay-hours/bonus data, retaining the underlying records for at least the same period (4 years) is consistent with broader statutory obligations and good practice.

In addition, the Act requires that the “pay transparency report … must continue to be available until the employer makes available a new report”.

Practical recommendation:
You should document your fair-pay analyses (methodology, data, findings, corrective plans) and retain those materials for at least 4 years, and preferably longer (e.g., 5-7 years) considering possible future audits, stakeholder inquiries or your organization’s evolving size/status. Ensure you have versioning or archival procedures so that you can reconstruct past analyses if needed.

3. Do you have reporting obligations under the Act?

Depends on your size and status. Right now, given your staff size (12 at one location + 30 at the other = total ~42 staff, excluding contractors) your organization likely falls below the current threshold for “reporting employer” under the Act.

Key points:

The Act phases in the “reporting employer” requirement by size:

-By November 1 2024: employers with 1,000+ employees must prepare & post a report.
-By November 1 2025: 300+ employees.
-By November 1 2026: 50+ employees.

Until you meet the “reporting employer” threshold, you are still subject to the other core obligations of the Act (job-posting salary disclosure, prohibition on asking pay history, anti-reprisal protections).
If you ever grow to meet/ exceed 50 employees by January 1 of a reporting year, you would need to prepare and publish a pay transparency report by the relevant November 1 deadline.

So for your current organization:

You likely do not yet have to prepare and publish the annual pay transparency report, but you should be ready: begin implementing policies, data-collection, and analysis readiness so that if/when you cross threshold you are compliant.

You must comply with:

-Including expected pay or pay-range in publicly-advertised job postings.
-Not asking applicants about their pay history (unless publicly available).
-Ensuring employees are not penalized for discussing pay or asking about the pay transparency report.

What this means for your organization (recommendations)

Given your size and current practices, I would suggest you treat this proactively:

Maintain your regular fair-pay analyses (you’re already doing them) and document them thoroughly (data, methodology, findings, corrective actions).

Update your job-posting templates so that any publicly-advertised roles include a realistic pay range (not “$ TBD” or “starting at”).

Review your recruitment documentation to ensure you do not ask applicants for their past pay history.

Update your pay transparency policy or procedure (and incorporate into your HRIS or tracking system) so you have:

-Mechanism to collect gender category disclosures (voluntary) when required.
-A process to provide employees an annual opportunity to update their gender/identity data.
-A defined archive/retention process for pay-data, analyses and reports (4-5 years minimum).

Monitor your employee count — if you approach or cross 50 employees, begin preparing for the report requirement (data-architecture, drafting the first report, publishing on a publicly-accessible site).

Communicate internally: Let your staff know that you’re implementing fair-pay transparency practices, that you comply with the Act, and that you protect employees who ask questions or share pay-related information.

-HRInsider Staff

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