What is the I-9 and why is it important?

I-9 is only relevant for organizations that have operations in the United States. It is one of the most critical pieces of paperwork that is completed by a new hire in the US as part of their Onboarding process into an organization; it is the new hire’s responsibility to provide the documents required to prove their legal status. The onus of verifying the authenticity of the document provided is upon the organization. It is mandated that this process of I-9 Verification be completed by the organization within 3 business days from the new hire’s start date.


How SF Onboarding helps with I-9?

With SF Onboarding, new hires can complete and e-sign the I-9 form during the New Employee Step. Upon the completion of the New Employee Step, in the Orientation Step the Corporate Representative can verify the legal status using the paperwork provided and upload a scanned copy of the same into the Onboarding system.


What are the requirements for electronically managing and storing I-9 information and form?

The USCIS website provides guidelines for managing and storing I-9 information of employees by an organization.

“Employers may use a paper system, an electronic system or a combination of paper and electronic systems to store Forms I-9. An electronic storage system must:

  • Include controls to ensure the integrity, accuracy and reliability of the electronic storage system.
  • Include controls to detect and prevent the unauthorized or accidental creation of, addition to, alteration of, deletion of or deterioration of an electronically stored Form I-9, including the electronic signature, if used.
  • Include controls to ensure an audit trail so that any alteration or change to the form since its creation is electronically stored and can be accessed by an appropriate government agency inspecting the forms.
  • Include an inspection and quality assurance program that regularly evaluates the electronic generation or storage system, and includes periodic checks of electronically stored Forms I-9, including the electronic signature, if used.
  • Include a detailed index of all data so that any particular record can be accessed immediately.
  • Produce a high degree of legibility and readability when displayed on a video display terminal or reproduced on paper.”

How SF Onboarding fulfills the requirements for electronic I-9 process?


Question: Does SF Onboarding include controls to ensure the integrity, accuracy and reliability of the electronic storage system?

Answer: SF offers multiple layers of security which includes your Company ID and Password policies and system access permissions. Apart from this, there is the over-arching data security at the datacenter level.  All data created within a client instance is stored in servers in the relevant data centers. This data is encrypted at rest (in storage) and in transit during integrations within other of SuccessFactors modules like Employee Central, Recruiting etc. Customers also have the option of encrypting data when it is sent to SF SFTP sites for integrating with third party software.

Apart from all of the above, if the organization is using an On-premise HR software like SAP HR, the data is sent back to SAP database tables which resides in servers maintained within the organization.


Question: Does SF Onboarding include controls to detect and prevent the unauthorized or accidental creation of, addition to, alteration of, deletion of or deterioration of an electronically stored Form I-9, including the electronic signature, if used?

Answer: Once the I-9 form has been completed by a new hire in the New Employee Step they can digitally sign the I-9 form. The system automatically creates a task for the corporate representative to verify the documents, to scan and upload the same and to digitally sign the I-9 form. Upon completion, the system generates a PDF of the I-9 with the signatures; the form is also locked for editing after the signatures have been finalized. This prevents any unauthorized creation or alteration of the electronic form. Below is a sample of signature validation provided by SF Onboarding.

Digital Signature Verification.png

Question: Does SF Onboarding include controls to detect and prevent the unauthorized or accidental creation of, addition to, alteration of, deletion of or deterioration of an electronically stored Form I-9, including the electronic signature, if used?


Answer: Apart from the password/SSO used by employees to login to their SF instance, Onboarding has its own password, which is required prior to electronically signing any paperwork within the Onboarding system. This also provides an additional layer of security.

Once the signature step has been completed, the Onboarding administrator in the organization can search and retrieve activities using the Search Work Queue functionality in the Onboarding dashboard. Below is the screenshot of the dashboard, Onboarding also provides an audit trail (in the work queue) of every  step in the system for each new hire and also provides a review of the information entered in the panel in read-only format.

Onbaording Dashboard.png

Review ReadOnly.png

Audit Trail.png

Question: Does SF Onboarding include an inspection and quality assurance program that regularly evaluates the electronic generation or storage system, and includes periodic checks of electronically stored Forms I-9, including the electronic signature, if used?

Answer: One of the key benefits of using cloud software is the minimal system maintenance and upkeep is taken care of by SAP. So evaluation of electronic signature and other functionalities is constantly being taken care of by SAP. Apart from this, the quarterly upgrades also help improve product functionality. SAP has is in the works of establishing integrations with DocuSign for Onboarding e-signatures.

The organization’s HR Department own the data submitted by a new hire and the responsibility of spot checking completed I-9s and data contained within. It also the responsibility of the HR Department to work with their HRIS Analysts to frequently test their systems and apply any available updates to their system as they see fit.

Question: Does SF Onboarding include a detailed index of all data so that any particular record can be accessed immediately?

Answer: SF Onboarding comes with its own document library (for all customers at no additional costs) called Document Center. The document center is the sole repository for any and all document created within the Onboarding module.

The Document Library can also permissioned to restrict access to the forms. For e.g. payroll department can be provided access only to W-4 forms, Recruiters can be provided accesses to I-9 forms etc.

Onboarding software available in the market today are intended to be transient systems which means that it is only a static document repository and is not designed to manage documents stored. All clients (HR Departments and HRIS Analysts) should take proactive steps to download the forms of the new hires and upload it into their HRIS. SF Onboarding has integrations that can be setup with Employee Central to automatically send critical data like SSN etc. back to EC. EC can also be configured to save attachments and clients should use this to store their completed I-9 forms. This provides for easy indexing of forms to the individual employee record and ensures easy retrieval when required.


Question: Does SF Onboarding produce documents with high degree of legibility and readability when displayed on a video display terminal or reproduced on paper?


Answer: Yes.

To conclude, I would like to say that SF Onboarding is a product that is evolving on a day to-day basis and so is the USCIS regulations for storing the I-9 along with the information contained in the I-9. The SF Onboarding product has a lot of useful functionalities that help in mitigating the time spent by HR on transactional data and day to day maintenance. It is the responsibility of every HR / HRIS Department to take proactive steps to thoroughly understand and learn the system to derive the maximum benefit from it. There are plethora trainings and manuals provided by SAP to empower system administrators.  The SAP Implementation Partner that the organization is working with should also provide guidance on system functionality during implementation and trainings prior to Go-Live for the customer to derive maximum ROI from their investment.


References:

https://www.uscis.gov/i-9-central/retain-store-form-i-9/storing-form-i-9

Validating digital signatures, Adobe Acrobat

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