www.bdo.ca PrivateCo Series: Talent HUMAN RESOURCES AND PAYROLL ACCOUNTABILITY Business issues impacting private companies What processes does your Human Resources department use to make sure they get all relevant information collated and keep it right? The repercussions of error can impact regulatory compliance, financial reporting, employee trust and dissatisfaction, as well as increase the propensity and likelihood for fraud. Well thought out processes and controls, coordinated with Finance, can mitigate these risks. The payroll process in most organizations is much more than just preparing pay cheques. It represents a true supply chain of processes and the movement of critical information, which needs to be managed closely for secure, accurate and timely processing. The life cycle of these processes includes: • Hiring employees and creating personal profiles • Recording time worked and incentive compensation eligibility • Calculating payments, disbursement of payroll (including income continuance) • Regulatory reporting and processing terminations These processes typically will be owned and carried out by both HR and Finance department functions in an organization. The processes are complex, require the intervention of many, and need to be accurately executed. Automation of processes usually provides the basis for more accurate and secure processing but, at the same time, introduces other processing risks that need to be managed. The repercussions of error can impact regulatory compliance, financial reporting, employee trust and dissatisfaction, as well as the propensity for fraud. How can an organization manage its payroll risks in a way that will minimize its exposures to error? Regardless of size, an organization needs to ensure there is close interaction and effective coordination of effort between HR and Finance. The root cause for many ineffective payroll environments is the lack of clarity of ownership and accountability. Where does the responsibility of Human Resources end and where does it begin for Finance? The results of how an organization decides this may vary based on size, systems complexities (HRIS interfaces with payroll systems) and outsourcing situations. The principles of defining ownership and accountability must be in place. There are three key steps that should be considered when developing a system of internal control over the payroll process. Ownership of your personnel information The first important question an organization needs to ask is who owns the personnel data? In almost all organizations the answer will be HR. Assuming this, it makes sense to let HR take ownership and set the ground rules of how the information needs to flow in order for the payroll system to work as it needs to. A common and very effective way to outline ownership and accountabilities is through a service level agreement (SLA) between HR and Finance. The SLA is intended to describe the full supply chain of processes required for payroll, as well as identify who does what together with the expectations of how – parameter setting with performance measurements. HUMAN RESOURCES AND PAYROLL ACCOUNTABILITY It goes to the level of detail, which will require: • • • • • Documented process mapping of all key processes Definition of exceptions and approval authorities Setting of company policy for information protection/ privacy Documenting user access levels to the system Setting guidelines for outsourcing, if necessary The SLA is a very detailed document and, prior to finalization and agreement, will require Finance involvement and input. Processing guidelines The supply chain can be broken down into three major areas: • • • Benefits changes (deductions for insurance, savings or taxable benefits) Vacation entitlement Systems access control levels Systems generated reports can be designed to highlight all changes and provide the means to have an independent person validate the accuracy of these changes. In addition to managing these, it is important that a complete validation of the system is performed at least once a year. This exercise is similar to an inventory count to verify balance sheet assets. HR represents a significant expense to an organization and it is important to be able to demonstrate and attest that only legitimate staff are being paid – that all staff exist and can be accounted for. 1. Entry of personnel into the organization Exit of personnel 2. Maintenance of payroll payments It is critical to ensure personnel profiles are retired accurately and on time. It can be a concern if pay cheques continue after someone has no longer any entitlement to receive payment. Regular validation edits are important to ensure only valid employees continue to be on the payroll register and continue to be paid. 3. Exiting personnel from the organization. Each of these includes risks and considerations for HR to mitigate. Entry of personnel A significant amount of paperwork is completed when a person first joins an organization. It is important that the sources for all inputs into a person’s profile (used for payroll) is defined and retained. HR needs to ensure that processes include input and validation checks and balances, and that authorization levels cannot be compromised. The set-up process is critical to ensure proper payment. HR should send out an inventory listing to each cost centre as a periodic and independent validation of completeness and accuracy of the payroll register. HR is also at risk for income continuance, in which case an employee has been terminated with severance. Rather than a payout, the arrangements are to continue to pay the employee for an agreed amount of time. It is important that these situations are monitored and do not continue beyond the agreed end date. Maintenance of payroll payments Compliance with regulatory requirements Changes to personal profiles create the big challenges and the real risk to the payroll system. HR needs to identify all change situations and incorporate regular edits or validation processes to ensure the changes have been executed correctly. Some of the more critical changes would include: It is very important that HR understands the regulatory environments in which its organization operates. This will include everything from minimum wage and vacation rates to tax deduction remittance requirements. Each requirement needs to be carefully overlaid onto the process maps so that control processes can be tested to ensure compliance is in effect. The sensitivities around identity theft and privacy of information (including the regulatory requirements) have heightened the need for tight data security. HR needs to be in a situation that can demonstrate how data is secured. • • • Salary Promotion or rate changes Incentive payouts HUMAN RESOURCES AND PAYROLL ACCOUNTABILITY Conclusion HR plays a key role in ensuring the integrity of an organization’s payroll system. Many organizations have tenured HR and Finance personnel who have managed the payroll processes for years without issues. While experience is important to a large degree and can be relied upon when managing risk, in today’s environment it is not enough. Organizations are becoming more complex, compensation structures more varied and regulatory requirements around privacy more restrictive. It is incumbent upon every organization to demonstrate a documented understanding of its processes and control environment, specifically its ability to maintain an accurate, complete and secure data base of personnel information. Third party audits are very common. Typically, these will be performed by the organization’s external auditors and periodically by the regulators. HR would be well positioned to take the lead in demonstrating how its supply chain of processes and controls operate. These must be documented and stand the test of time – i.e. updated, current and relevant to its process owners. PrivateCo Series: Business Issues Impacting Private Companies With over 90 years of experience closely working with private companies in Canada, we help our clients approach the significant challenges and opportunities they face in a competitive and evolving marketplace. Our professionals offer accounting, taxation and advisory services to over 50,000 clients across Canada, combined with strategic advice and an emphasis on delivering excellent client service. We help organizations gain their footing as they strive to expand into new markets, plan for the future, manage risks, develop innovations, and improve their bottom lines. The PrivateCo Series of articles addresses the eight business issues that we see our clients face on a regular basis through the life cycle of their businesses. To learn more about BDO and our services for private companies, please visit our website: www.bdo.ca/private-companies If you have any questions on the above, please speak to your usual BDO advisor. This article in our PrivateCo Series was developed in partnership with Nick Bako of Nick Bako and Associates. BDO Canada LLP, a Canadian limited liability partnership, is a member of BDO International Limited, a UK company limited by guarantee, and forms part of the international BDO network of independent member firms. BDO is the brand name for the BDO network and for each of the BDO Member Firms.