The Importance of the Audit Trail for Digital I-9s

It’s clear that digital I-9 and also E-Verify systems can use countless advantages to companies seeking to boost as well as simplify their employment qualification verification process. There are many compelling factors for going digital, not the least of which is the ability to shred all of those untidy paper forms after your records have been investigated and converted into an electronic style. What many companies neglect, nonetheless, is that the federal government’s objective behind digital I-9s is not only to help with company conformity, however also to enhance the enforcement of the law. So while it’s certainly a great idea to streamline your operations (with a smart, digital I-9 system), it’s just as crucial to conduct a complete testimonial of possible electronic I-9 remedies to ensure they’ll take on an ICE investigation.

The Audit Route

There are a host of elements that you must take into consideration in selecting an electronic I-9 system. These variables consist of safety and security, usability, expense effectiveness, and also the ability to track usage or “auditability”. A few of these aspects are employer-driven, whereas others stem from the legal needs defined in the ICE acting final laws covering electronic I-9s (which are soon to be made last).

Among the much more plain stipulations in the guidelines states that ICE can essentially “revoke” an electronic I-9 (claim a company did not do one) if one of the “recordkeeping criteria” has actually not been fulfilled. Why exists such an oppressive arrangement wherefore several would consider an innocent management blunder? Essentially, everything boils down to the trustworthiness of a digital document. In the paper globe, an auditor can analyze the ink on the form, the handwriting, proof of alterations, etc. On the other hand, an electronic type (in straightforward PDF) yields none of these hints for an examiner to assess.

To overcome this concern, ICE consisted of a relatively broad yet considerable need for a digital I-9 system: it should have the ability to create “the online kept Types I-9, any sustaining documents, as well as their connected audit routes, reports, and also various other data used to preserve the credibility, integrity, and dependability of the documents.” What does that suggest? Somewhere else in the law, ICE clarifies that an audit trail is a record showing who has actually accessed a computer system as well as the actions done within or on the computer – which is taken to mean that everything that takes place in the system should be key logged, traceable, and reviewable by an accredited agent.

Appears simple enough, right? Computer system systems are currently monitoring our every proceed the Net; should not be a big bargain for an electronic I-9 system to do so. Well, yes and no.

Yes, it is possible for a digital I-9 system to accomplish this degree of sophistication via a comprehensive as well as well-planned structure that combines in-depth occasion as well as user monitoring as well as internal controls to make sure the stability of the procedure. Implementing such a system, however, needs a layout choice (for the supplier) that is challenging to carry out as well as expensive to keep. Numerous software program applications fail in this regard, providing only the basic “material modification of information” audit path which shows simply the vital relevant adjustments (or milestones) to the I-9 document. Regrettably, this doesn’t truly tell the whole story, and also if you remain in the awkward setting of speaking to an ICE forensic auditor, the whole tale is what you need.

For example, a tiny business transformed over to an electronic I-9 system concerning 2 years earlier. This system was offered by their pay-roll firm, and also was offered to the firm on the theory that the pay-roll business would be dealing with all their staff member’s demands as it pertaining to work. This is not a negative pitch, particularly to smaller sized companies that do not generally have the capacity to completely staff a HR division. Sadly for this company, a year later on ICE was available in and asked to investigate every one of the I-9 records for its around 50 employees. During that year of I-9s the company had actually integrated regarding 100 I-9s right into the system, consisting of 30 new hires. Yet, there was no electronic tracking system in position for the I-9s, no other way to understand if the I-9s had actually been completed prompt, and no other way to understand if the I-9s had been modified whatsoever. This company is still prosecuting these problems, as well as is dealing with serious penalties, even though their electronic I-9s “appeared” penalty.

In audits of electronic I-9 systems, ICE investigators take the approach that every aspect of that electronic system have to be “auditable,” To put it simply, ICE wishes to have the ability to validate that went into each item of information, what was gotten in, and also when they did so.


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