We catch missed breaks, unpaid break premiums, and open safety items — then chase each one to a documented fix.

Per-shift, end-of-day, end-of-week, or per pay cycle — whichever fits the operation. Captures meal and rest break compliance, hours accuracy, and pay-match in the employee’s own words. The same crew-facing surface carries the other records California already compels: the IIPP hazard and correction record (8 CCR 3203), the SB 553 violent incident log (Lab. Code §6401.9), §3395 outdoor and §3396 indoor heat training documentation, and the FEHA policy acknowledgment and harassment-prevention training records (2 CCR §§ 11023, 11024(b)(2)). Different statutes, different remedies, no shared mechanism — but the employer owes every one of them anyway, so there is no lawful posture in which they do not exist. Spanish where the workforce needs it, scoped in the records diagnostic.

Each pay period, every flag — from your time and payroll records and from the sign-off — is worked with your team under the attorney-reviewed protocol: what to do, in what order, and what to enter on the record. A missed or short break is caught the pay period it happens, and nothing closes without a dated entry. The point is to close the item, not to count it. The statute names corrective action among its examples; nothing names detection.

When the same employee misses three breaks in two weeks, they get a short, role-relevant course — not blanket annual training the whole crew sat through. The supervisor who kept signing off on it gets routed too: Supervisor training and corrective action as to supervisors are two of the four examples of reasonable steps Labor Code §2699(g)(2) names. Both courses run in English or, where the crew needs it, Spanish, and completion lands on the audit trail with a timestamp.

Entries are recorded every pay period — timestamped, signature-captured, tamper-evident — not assembled after a claim lands. A correction is entered beside the item it corrects rather than over it, so the original entry and the fix both stay readable. Structured, queryable, and built in evidentiary format from the first pay period rather than reformatted later.

The record is held by your own authorized custodian of records, not by us, so producing it is an export rather than an assembly job. One production package is the records export your authorized custodian of records produces to answer a lawyer’s letter demanding records. When that letter arrives — a request under section 226, 432, or 1198.5 — or a §2699 PAGA notice after it, that custodian of records — never Floburn — produces one production package in hours, not weeks, and authenticates it as the person who has held it all along. The timeline is a property of how the record is kept, not a promise about your matter. No outcome is guaranteed; every matter turns on its facts. If the engagement ends, the closing export is part of offboarding: Floburn operates the loop, your company owns the record.

Labor Code §2699(g) caps PAGA civil penalties at 15% where the employer took all reasonable steps before notice — or before an employee’s personnel or payroll records request, which often comes first; §2699(h) caps them at 30% for remediation within 60 days after. Two qualifications matter. Whether the steps were enough is the court’s call, on the totality of the circumstances. And the percentages are ceilings, not floors: §2699(e)(2) lets a court award more, “notwithstanding the limitations set forth in subdivisions (g) and (h).” The cap reaches Labor Code civil penalties only, it is conditional on evidence rather than policies, and no record means no cap.

§2699(g)(2) names four examples: periodic payroll audits with action taken in response, lawful written policies disseminated to employees, supervisor training on Labor Code and wage order compliance, and corrective action as to supervisors. Reasonableness is judged “on the totality of the circumstances, taking into account the size and resources available to the employer.” Each item must be shown — with timestamps, signatures, and a chain of custody that survives discovery — and we produce a dated, exportable record of all four. The same subdivision adds the part employers rarely hear: “the existence of a violation, despite the steps taken, is insufficient to establish that an employer failed to take all reasonable steps.” Being imperfect does not forfeit the argument. Policies that exist only in a handbook, with nothing showing they were distributed or followed, are what forfeits it. No California appellate court has yet said what satisfies “all reasonable steps.”

As amended by the 2024 reforms, §2699(g)(2) names four examples of “all reasonable steps”: periodic payroll audits with action taken in response, lawful written policies disseminated to employees, supervisor training on Labor Code and wage order compliance, and corrective action as to supervisors. LWDA proposed its first PAGA regulations in February 2026; they are procedural — notice content, filer conduct, settlement review — and do not interpret the reasonable-steps standard. They are proposed, not final, and nothing on this page assumes they take effect. Reasonable steps are shown by evidence, not assertion — a record tied to specific employees, dates, and times.

It is the time data — clock-in, clock-out, GPS, geofencing — which is the input, not the record. Several timekeeping products can capture a signature at clock-out, and the box is sometimes configured long before anyone asks who acts on what it surfaces. Your system may have a sign-off box; what matters is whether anyone acts on what it surfaces. An app can capture a signature, but it will not chase the exception, pay the premium, retrain the foreman, or close the item. What the sign-off adds is evidence about whether breaks actually happened: the employee’s own contemporaneous affirmation or dispute that breaks were taken, hours are accurate, and pay matches expectation. The correction is then entered alongside anything that came back wrong. MicroForensics is built on top of the time clock you already run — it ingests the time data, routes per-pay-period attestations, and runs the correction to close.

No. MicroForensics sits above your existing HRIS, timekeeping, and payroll systems. We build the connector for your stack — by API where one exists, by export, SFTP, or structured manual entry where one doesn’t — scoped and priced in the records diagnostic. The systems we build on are listed under “What it runs on”. You keep your payroll and time clocks; MicroForensics reads from them.

Two different answers, and the difference is worth being plain about. On harassment: California employers are strictly liable for harassment by a supervisor — no record and no service changes that — and Gov. Code §12950.1(c) says training compliance “does not insulate the employer from liability for sexual harassment.” What the law does compel is a record: the FEHA policy acknowledgment and the harassment-prevention training records (2 CCR §§ 11023, 11024(b)(2)). The crew-facing surface carries both, dated and tracked to completion, because the employer owes them anyway. One textual point your lawyer may find useful: Gov. Code §12940(k) requires “all reasonable steps” to prevent harassment — the same words amended §2699(g) uses on the wage-and-hour side — so one record architecture answers both statutes’ phrasing. That is evidence and posture, not a statutory penalty mechanism. On discrimination: no. No California statute rewards documentation there the way §2699 does for wage-and-hour civil penalties — liability turns on the adverse decision itself, not on notice — so we make no claim on discrimination, and we would be skeptical of a vendor who does.

A waiver signed at hire establishes that the employee was informed of the meal-break rule. It does not establish that any particular break on any particular day was taken or knowingly waived. Donohue v. AMN Services (Cal. 2021) held that noncompliant time records create a rebuttable presumption of violation. The California Supreme Court described an employer system of the same per-period design and said that, without the rounding, it “would have ensured accurate tracking of meal period violations” — so we don’t round. Attestation prompts fire on unrounded punch times: Where a customer’s timekeeping rounds punches, deployment turns the rounding off, and where unrounded punches can’t be supplied, we say so rather than prompt off rounded data. Be clear about what that is and isn’t: No court has ever held that an employee attestation rebuts the Donohue presumption, and Donohue itself left sufficiency for remand. The hire-day signature is policy. The contemporaneous attestation is dated evidence your lawyer can argue from. Neither is a ruling.

You keep it — that is a design decision, not a courtesy. The record is built in evidentiary format from the first pay period, your authorized custodian of records holds the standing export, and the exports are structured, queryable files your lawyer or a successor vendor can use without us. Floburn operates the loop; your company owns the record. If the engagement ends, the closing export is part of offboarding, and nothing about the record’s usability depends on Floburn continuing to exist.

If all reasonable steps were taken and documented before the notice, §2699(g) caps civil penalties at 15% — applied by the court on a totality-of-the-circumstances showing, and subject to §2699(e)(2), which lets a court exceed the limits. If documentation is incomplete, §2699(h) caps penalties at 30% for remediation within 60 days after. MicroForensics can be implemented inside that 60-day window. Separate pathways exist by headcount: Employers with 100 or more employees can request a court-supervised early evaluation conference; employers under 100 can propose a cure — correcting the violation and making each affected employee whole — on a confidential LWDA path with its own short clock. Which pathway applies to you, whether you qualify, what to cure, and what your exposure is are legal conclusions on your facts. Your lawyer makes those calls; we build the material they argue from, and the earlier we start the more of it there is.