Ask HN: Why is Pave legal?

1098 points by nowyoudont ↗ HN
If you haven't heard of it, Pave is a YC-backed startup that helps startups with compensation. I can't actually access the system so I'm speaking from hearsay and what's information on public parts of their website. The way I understand it works is that you connect Pave to your HR and Payroll systems, they take the data about who you employ and how much you pay them, combine it with all their other companies, and give companies a collective breakdown of compensation ranges.

My question is, isn't this specifically anti-competitive wage fixing? This seems exactly like RealPage but for employee compensation. As far as I know, colluding on wages like this is illegal. Is there something about the company that I'm missing?

521 comments

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I believe wage-fixing would require companies to agree to…fix wages. Having knowledge of average compensation is not inherently problematic. Firms are still able to decide to pay more or less than the prevailing wage.
RealPage also gave recommendations. Giving a salary range seems like the same thing.
By this logic, employees who share their salary publicly also contribute to wage fixing.
If it’s public there is no information asymmetry. There is no fixing.
How?

Information symmetry doesn't prevent fixing. E.g., rents are all public information.

If it is public, won't employers still have access to the salary ranges for free? The very thing Pave is giving them at a cost?

Do you actually believe they will be doing this?
"I believe wage-fixing would require companies to agree to…fix wages"

They don't need to officially twirl their mustaches and laugh evilly while telling each other how they're definitely fixing wages. They just need to share data on wages with other companies in the same or a similar business with the intent of decreasing wages. That is already illegal, because they're colluding with competitors to keep wages low.

The whole point of getting such data is to ... fix wages.
It’s new so the government hasn’t caught on yet. They probably also need a larger market share to be considered fixing.
ADP has a product called compensation benchmarking which is very similar to how this is described.

They’ve had that product (with various names) for years.

Experian also sells a similar product
No, this is not new. There are many many many companies selling compensation metrics. This is also not salary fixing. These companies typically do not offer recommendations. It's up to each individual company to decide how to structure their salary bands and how they want to stack up to the market.
I actually run a product in this space in Europe as part of my portfolio. To echo your recommendation point; How we do it is pretty much the industry works. We give the low, mid, and high points in our data set based on what variables you input. We get the data from salary surveys and government data sets.

It’s all very boring and above board.

If companies choose to talk to each other to suppress salaries, they’re not using our tooling to do it.

There are also firms that will do all this work for you especially if you lack enough people in your own offices for an internal benchmark. If you’re building a CAD tool you can tell them (paraphrasing) to pretend you’re just like Autodesk and ask how much you should pay a UI designer.

What is the name of your European product, and is that data solely available to employers?
Wage fixing is when multiple companies agree to set wages at a certain amount.

Sharing compensation data across companies doesn't necessarily mean wage fixing. Company A can use the compensation data from Company B to try and compete better for talent.

Not saying thats what it will be used for, but it's technically not wage fixing.

I'm asking this as someone with 0 legal knowledge: doesn't the context matter? If every company takes this data and is like "we want to pay at the 95th percentile" (which is what they all do), that seems like wage fixing even if they're not all agreeing to it together.
That’s how pricing works in a market?

In fact if every company did pay at 95th percentile then I’d say it’s a good outcome. There’s a 5 percentile slack which is not too bad?

If they’re all shooting for the 95th percentile and have up-to-date data then you certainly won’t have fixing; rather you’ll get insanely rapid wage inflation!
Yeah, it seems more like they'd all shoot for 45th percentile and say "We pay competitive wages" instead, slowly driving the wages down.
That's what my employer does. The head of our HR team got in front of the entire company and said that they aim for 50th percentile for everyone in every pay band. It instantly made me want to job hop, tempered only by the million things I have going on in my personal life that have a better expected value than a 5 or 10k pay bump.
That's... hilarious. We all know they are thinking that but to say it loudly and proudly to the employees is a self own on a level that makes me Cheshire Cat.
There's also a more cynical explanation.

It's possible the purpose of wage benchmarking companies is to allow bosses to say they pay the 95th percentile - which is useful to be able to say, when someone at an all-hands Q&A asks about raises and bonuses.

Then the benchmarking company simply has to define 'comparable roles' broadly enough to give the customer the result they want.

Not necessarily, if everyone's wages (except 5%) were set at minimum wage then the 95th percentile would be the minimum wage.
Which is... exactly what the software industry has seen over the past 30 years?
If you opened up a business selling water bottles, you'd probably check what price water sells at across brands, then decide in which segment to price it.

"I want to sell my water at the upper end and market it as a gourmet brand"

But in this case you're not selling, you're buying.
> If every company takes this data and is like "we want to pay at the 95th percentile"

It's thought by some that this is how CEO compensation has gone up so much: Corporate boards of directors have compensation committees, which are fed survey data about comp ranges; a comp committee will say, "We want our CEO's comp to be in the top quartile" — which, as time goes on, leads to an inexorable upward ratchet effect.

I think some basic math knowledge would help more, if every company paid at the 95th percentile then it wouldn't be the 95th percentile, it would in fact be the average. But no, these distributions are not flat like that, there is a large spread and "by definition" of the 95th percentile only a few companies pay at that rate.
Stochastic wage fixing is still wage fixing
unless you collude with other companies, doesn't seem like it is.
unless disclosed to employees and applicants this seems like de facto colluding.

I always ask myself, as to the legality or ethics, would this survive review by a jury of my peers...

You think it is more ethical for wage data to be kept secret? Why? Rarely is requiring secrecy the more ethical option.
What would be the least ethical would be keeping it secret to one party and having the other party sharing data... Oh wait!
Glassdoor exists.
>Glassdoor exists.

you are not allowed to tell anyone how much you make so you might be in trouble if your found out but the companies share this info without your consent. From my POV make it all transparent.

I have had a career spanning over 30 years at this point. I've worked in businesses with 6 employees and F500 corporations. No one has ever told me that I can't tell anyone else how much I make.
So... Pave shouldn't exists as "Glassdoor exists" and is already providing data?
Eh? Glassdoor is for the other party, which you were implying was being kept in the dark.
If Glassdoor data are sufficient, why would employers pay for Pave?

It's not like Glassdoor is restricted to employees, they even offer specific services to employers.

That is the entire basis for the RealPage lawsuit. The point is that if the effect on pricing is indistinguishable from price fixing, it doesn't matter if the act of colluding is abstracted into and laundered through a 3rd party with an algorithmic system responsible for setting prices.
Honestly, I think it does still matter. The basis for the RealPage lawsuit seems to be that people inside and outside the company glibly considered it price-fixing, and said it out loud to each other. The didn't really seem to make the case that it was "algorithmic price-fixing" (Disclaimer: not a lawyer). You can only argue in court about existing laws, so until algorithmic price-fixing is written in the law books (or settled case law) you're gonna have a tough time bringing that up to a judge.
It seems you don't understand the lawsuit. Most of the claims are based on the actual mechanics of how algorithmic price fixing does violate existing laws.
> Wage fixing is when multiple companies agree to set wages at a certain amount.

I am not an expert on wage fixing laws in the US, but I came across a class action on wage fixing a few days ago (Ron Brown et al v JBS USA Food Company et al) where part of what was aledged was the illegal exchange of salary data via surveys [1].

> The Red Meat Industry Compensation Survey conducted by WMS on behalf of the Defendant Processors violated the Safe Harbor Guidelines in at least three ways. First, the Defendant Processors, not WMS, collectively managed and controlled the annual Red Meat Industry Compensation Surveys. Second, those Surveys often contained information about the Defendant Processors’ future compensation plans and practices. Third, Defendant Processors had extensive discussions about the Survey results, including at in-person meetings, during which they disclosed their respective compensation rates, practices, and plans

[1]: https://www.classaction.org/media/brown-et-al-v-jbs-usa-food...

>part of what was aledged was the illegal exchange of salary data via surveys

Alleged doesn't mean illegal. In this case this point never saw court; the sides settled.

And what this claimed to have happened is not what is happening here.

> Alleged doesn't mean illegal

What is alledged is that they did that. And if they did, they would have violated the law from my understanding.

> And what this claimed to have happened is not what is happening here.

That might be, but that's not entirely clear to me. I don't know if what Pave is doing is legal or not, but it seems to me that the line is quite fine and it would be fascinating to see this play out at court.

>Company A can use the compensation data from Company B to try and compete better for talent.

My company has done this in the past sorta indirectly, we were losing a lot of people to competitors and data like this is how they justified paying a bunch of us better so we wouldn't leave. I agree that it could be used to fix wages, but companies will always have to pay their best talent more if they want to retain them, whether that means paying them above what the data says or if it means inventing new job titles for them to progress into.

> Company A can use the compensation data from Company B to try and compete better for talent.

Company A could make offers and negotiate with prospective hires based on the value they can get out of the hire. Rather than secretly leverage surveillance capitalism against the prospective hire, to base their offer on what the person is currently making (and, hey, if lots of employers do that by convention, you pretty much have collusion).

Huh, looks like they've pivoted (or is that a different Pave?).

> Pave: We turn your Google Analytics data in actionable insights + reports with our data science AI algorithm.

https://www.ycombinator.com/companies/pave

That proud phrase "HR Tech" in that link, gives me the heebie-jeebies.

I'd say "if you work in a company like this you're a bad person", but sociopaths, sorry, Wharton graduates won't give a shit anyway.

It seems like the term Wharton graduates is now a wart on graduates' resumes.
Companies like Radford have been doing this for decades and are used by pretty much everyone, Pave is just a more efficient version of the same game.
Beyond salary, there is a whole industry of data brokers who get transactional data from individual participants in an industry vertical (CPG, Health Insurance, Salary, etc), aggregate it with their competitors and present it back to those participants as benchmarks. Management Consulting likewise is a way to launder getting strategic insight into your competitors from a third-party.
There's a long long history--especially when a lot of information was more opaque than today--when companies quietly shared a bunch of information with middlemen because they needed that information from other companies to function and the middlemen skimmed some of the the take.

Even price sheets that we would consider very rudimentary today were part of that.

My guess is that they would argue that most of the data they use is public, just go on LinkedIn and look at 10 job listings to have a range.
Job listings is very different kind of data than compensation actually paid to employees.
Pave's data is _incredibly_ revealing. First of all it covers historical data for every single employee, secondly it includes stock as well. It also relates the compensation to performance.
This was the exact thing that popped into my mind when I read the poster’s description.
Reading that, seems like RealPage could protect itself from similar problems if they simply avoid using the same sales rhetoric, and don't do explicit recommendations. "You are paying way more for this position than others... hmmmm."

Surely they are aware of the similarities and are strategizing.

Soon you need to waive your class-action rights when applying for a job.
(comment deleted)
The OP specifically mentions that.
“I’m not punching you in the face, I’m just putting my fist on a movement vector that happens to intersect your face.” I hope these guys get their shit rocked in court. I’m tired of a world run by cartels.
"Alright, pie, I'm just gonna do this...and if you get eaten, it's your own fault!"
It's legal the same way Airbnb and Uber are legal.
Collecting and sharing data is in itself not illegal. RealPage was also using the data to algorithmically generate a rent number and encouraging landlords to automatically use that number with no room for negotiation. It literally branded itself as a service that would prevent landlords from bidding against each other. That part is what pushed it into collusion.

And regardless of whether it is legal or not, the problem has to go beyond a handful of small startups for the DoJ to get involved. RealPage is used in 80%+ of multifamily rental buildings in the US. What is Pave's market share? How many employees are affected by their practices?

> Pave is a YC-backed startup

This thread is getting removed from the front-page in 3... 2...

I really, really hope they don't.
Aaaaand it's gone.
This makes me sad.

@dang, can you comment on that? I appreciate your integrity.

We didn't see it or demote it—it set off the flamewar detector. I've turned that off now, in keeping with the principle described here: https://news.ycombinator.com/item?id=41511529.

p.s. @dang is a no-op - I only saw this thread because I was doing our standard review of the flamewar detector. If you want guaranteed* message delivery, hn@ycombinator.com is the only way.

* Well, mostly guaranteed. I assume there are a few that fail to get noticed in the spam bin, though we check that pretty carefully.

That's awfully convenient. You don't moderate the content, your flame war detector goes off, and the algorithm removes it for you.
HN, as with virtually all user-generated content sites, leverages both member actions and automation heavily.

Annually HN sees about 150k active users, 400k stories, and 4m comments:

<https://whaly.io/posts/hacker-news-2021-retrospective> (2021 retrespective by Whaly.io).

It has one public-facing moderator (and apparently a few others who don't post publicly on the site). HN's own mods see very little of the total site content. Automation and member votes, flags, and vouches, as well as emails to the mods, are what keep HN humming. Not perfectly, but quite frankly one of the better-run online discussion sites, and one whose quality has remained remarkably steady over nearly 20 years.

If you see something you think isn't right (bad content not flagged, good content flagged, whatever, email the mods, and they'll take a look. I do this a lot myself, usually with positive results.

I thought this was a joke comment but I went back after reading the comments and it’s now on the second page already.
It was at #3 for me and then suddenly demoted to the second page. It's pretty common for these touchy-YC threads.
Page 3 now.
211 points in an hour, and now page 4.
#10 on the front page now
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I understand why people assume we do that, but actually we do the opposite—that is, we moderate less when YC or a YC startup is part of a story. There is plenty of past explanation at https://hn.algolia.com/?dateRange=all&page=0&prefix=false&qu....

Note: we still moderate such threads. We just do it less than we otherwise would.

If this were illegal, so should the KornFerry Hay system be, and that system has existed for decades.
Lol try this here in EU.
It exists, many companies are using wage benchmarks to fix salary in EU.

Companies assume they don't need your approval to collect data on salary range for your position as aggregates are not directly pointing at you.

Gratitude for the expose. I was(and assume most here were as well) completely unaware of Pave. I will, and hopefully other potentially impacted, look up if I am affected by this and if so - share experiences/info here.
Wow first we got our rents fixed, now we're getting our wages fixed. Awesome
Using a rent estimate would be a brilliant way to double-check if you are overpaying salaries. /s
Been going on for a while:

High-Tech Employee Antitrust Litigation is a 2010 United States Department of Justice (DOJ) antitrust action and a 2013 civil class action against several Silicon Valley companies for alleged "no cold call" agreements which restrained the recruitment of high-tech employees.

<https://en.wikipedia.org/wiki/High-Tech_Employee_Antitrust_L...>

Because it's not wage fixing?

To be competitive you need to be paying more than others not the same as them. This is why FAANG got themselves into a fix of paying 500k for people they would have paid 200k for a year or so beforehand.

I got access to Pave through one of my investors. Seeing the data made us set salaries and contractor rates higher, not lower. It’s like salary banding at big companies. It’s a framework for how much other people are paid at the same level, not a contract. HR will make it seem like a rule, but if you do spectacular work - you can always negotiate.

Collusion requires an agreement between rivals that negatively disrupts market equilibrium. Is this company not actually making the market more efficient and transparent? That said - an efficient market is good for the collective, not necessarily the rogue / outlier individual.

The market might be more transparent for the people who have access to pave, but for those who dont, the information asymmetry becomes worse.
Ding ding ding. Improving information for only the already-more-powerful side of such an asymmetric relationship doesn’t help the weaker side.
I agree and as an employee I encourage everyone to take a second post their salaries on levels.fyi. We have our own compensation tool that is free & likely as good or better than Pave as long as people add their info.
> Collusion requires an agreement between rivals that negatively disrupts market equilibrium. Is this company not actually making the market more efficient and transparent? That said - an efficient market is good for the collective, not necessarily the rogue / outlier individual.

I'm sure you practice what you preach and tell all your employees what their coworkers earn?

I'm sure he means transparency in the market where employers are competing with each other, not the market where individual employees are choosing employers

With a few exceptions, I've found that companies that talk about transparency are transparent with everything but employee salary

> HR will make it seem like a rule, but if you do spectacular work - you can always negotiate.

Every single developer should take this to heart. The phrase I once used at the end of an annual review was, "you can't give me a review like that but a raise like this!"

Yes, my manager had to get permission to give me the % increase I wanted, but it was to his benefit to do it since he wanted me to stay.

> Is this company not actually making the market more efficient and transparent

No, not at all. Unless applicants/employees get full access to the same information.

Ok, so your company ended up raising salaries because you were underpaying. That certainly wouldn't be the case if you found out your salaries were ABOVE average. You'd keep it the same at best, but most likely lower it.

That's the point of these systems. If it's not illegal, then it should be.

Or at any rate, "as one member, we ended up spending more when we started participating in a thingy" isn't super-strong evidence that the thingy is OK.

__________

To illustrate this, imagine some kind of over-the-top incontrovertible conspiracy to depress wages. I'm talking a secret volcano-island base, a letterhead with a Et redigam operarios in servitutem in latin, members greeting each-other as "Hello, fellow conspirator!" while twirling deliberate Snidely Whiplash mustaches, etc.

Then a new company joins the cartel, and it turns out that company was one of the ones previously paying below the fixed-price.

The fact that some members pay more on joining doesn't change the core nature of the system, especially if there's "noise" in the organic prices.

Well, I wouldn't mind getting my wage fixed, if that works both ways, down _and up_, because then I would be guaranteed to never earn less than average for my skill and experience. Assuming, that those things of course factor into the averaging. Person X with experience Y in position Z. However, something tells me, that there is a tendency towards the downwards direction and none towards wage increase.

(Background: In Germany not so many companies pay competitive wages for their software engineers, especially not, once you worked for some years and are no longer a bloody junior. So I calculate it would result in a wage increase for me, since everyone says I am underpaid for my experience.)

Genuine question: What makes you believe that an employer would decide to pay you more when they notice that they're paying you less than other companies would? Why wouldn't they just think "Oh, neat, we got such a bargain!"
That's the reason I wrote, that I wouldn't mind, if (and only if) the upwards direction also happens and why I wrote, that "something tells me" that that wouldn't be the case ; )
If they cannot fill positions or are shedding talent.
What stops senior devs in Germany from remote contracting for foreign companies that pay better?
Not everyone wants to be self-employed is at least one factor.
That's a significant factor here in Taiwan, also.
Not to mention being self-employed here is a lot more complicated and expensive than in most jurisdictions. Things like having to meet strict professional definitions before being allowed to freelance (not usually an issue for engineers, but I know folks who've got into trouble because of the lack of a bachelors degree).
If you're truly underpaid for your experience and location then you should be able to get a new higher paying job easily. And if you can't easily get one well maybe you aren't underpaid.
Yeah this is borderline. It probably won't fly in California. In the past big tech companies (like Symantec) used to require you to submit your last W2 or tax return for a job offer. Credit card companies also sell your salary information etc...
This sounds very obviously illegal. Where is the local DA on this?
In the UK and EU it would be outright illegal on GDPR grounds (unless you consented to it, which would be unlikely without coercion — also illegal)
In the EU there are definitely companies providing aggregated salary band norms, in fact utilizing them is nearly required by upcoming EU directives as salaries must be justified by HR. In the Netherlands I know Bureau Baarda is gathering and selling data.
Pave (and many other comp platforms) are prolifically used in the UK and across the EU because no individuals personal data is being shared. Pave doesn't get told 'louthy is a software engineer and gets paid £50k a year' - they get a list of job titles, seniority, and salaries but no identifiable data.
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The fundamental difference between something like Pave or Radford is that, AFAIK, they are simply providing companies with information.

I am not a lawyer, but I believe the fundamental issue with RealPage is that by entering into a service agreement with them, you agree not to violate their price “recommendation” and so you are centralizing actual pricing power into a single entity.

I believe RealPage has some way to negotiate out of this standard deal but it’s not common.

Companies likely insist on staying within certain pay bands for a whole host of legal and HR reasons but they aren’t getting a specific salary from Pave that they are contractually obligated to use in their offer.

I can recite at least five situations where "simply providing X with information" is considered a crime. One of them is company A providing planned price to company B in order to agree on it, and it is called price fixing. Other are insider trading, pump and dump, etc.
1) Salary surveys for local or national startup scenes have been a staple for decades. Here in Waterloo (Canada), there was a dominant local survey that all tech companies participated in annually with results being shared. Then, as you get bigger, you come across larger versions of the same thing.

2) VCs are often the vector by which this all happens. They ask their portfolio companies to pull together the info for their employees, presumably submit it into the companies aggregating everything, and then the startup gets a copy of the recent data.

3) Even done the old way (Excel), the data was incredibly detailed. You can slice and dice by startup stage (series A vs series B vs seed), employee count, region, sector, etc to determine if you're paying market rates or not. This is particularly useful for growing startups, where the founders have no idea what to pay, say, a VP Marketing at their pre-revenue mobile gaming startup in Helsinki.

4) Obviously whether or not this is bad for employees themselves is debatable, but I think people are missing the point that these surveys are ALWAYS skewed UPWARDS due to the much higher volume of data from the large tech companies (because they have far more employees and tend to be offering significantly higher comp). So in practice, the impact is likely to RAISE wages at earlier stage startups who are competing for the same talent as later stage tech.

An interesting artifact of the information disparity between the startup executives (who have access to this benchmark data) and the employees (who don't) is that the employee is often wildly off the mark in their expectations, either too low or too high.

There are so many variables at play too that it turns into a negotiation like everything else. Say an employee wants a big raise because they are having their first child are heading towards a higher cost base at home. Say the employer simply says "the salary data shows that your current pay is at the market average".

Well, is the employee truly "average"? Perhaps they're a high performer. Does the average number take into account not only the company dynamics (stage, domain, funding, revenue level, etc)? Not perfectly.

But then on the other side, just because an employee wants a higher salary due to a higher cost structure at home doesn't mean they are automatically entitled to it, right?

Then on the startup side again, the manager is looking at the data and thinking about all the time and cost of replacing this person and realizing it's likely more than the cost of just granting the raise.

Then the HR person comes in and says the salary grid -- whose whole purpose is to provide in theory tight constraints on these conversations -- rules this all out, there's no budget or wiggle room. When the Manager suggests the grid hasn't been updated in a few years, HR takes it personally and tells the person to take it up with the CEO.

So then the CEO gets involved. She knows the employee has a unique view on the technology and market direction and considers them Tier 1 can't-lose-them. She knows the grid is out of date. She looks at the data and thinks that she can justify to herself and the financial plan that it'll be OK to do it, with fingers crossed that this doesn't happen across the board because then their runway will shorten considerably.

So the raise happens.

My point is just that the salary information asymmetry is just one relatively minor aspect to this whole negotiation and in the end I'm not sure it advantages the company all that much.

I guess my issue with all the “it’s just info” arguments is this. Employers inherently have an information advantage in salary negotiations. A tool like Pave drastically increases that imbalance.

How am I ever going to realistically negotiate salary vs a company that has this level of information (even during performance reviews)? And frankly something that worries me is, what level of data are they getting? If it’s tied to your HR system, does it get anonymized performance reviews? If every company can perfectly profile me and place me in an expected salary, I as the employee give up all my power. That’s strictly bad for me

Your salary negotiation point speaks more to a call for open salary data, which many people have been arguing for.

You're missing a lot with your second point though. If a company has excellent salary data and can put in you a band, then it also means that you have better grounds to argue for raises when you gain experience, or argue if you are underpaid, or even find jobs at companies who intentionally pay a higher percentile to market as a way to attract better talent.

In contrast, if we all operate 100% blind with no data, as many here seem to want, it would lead to all sorts of unfair wage situations with people doing equivalent jobs earning vastly different amounts. This sort of environment is biased towards more aggressive people who have strong social skills when it comes to negotiation. In fact, you see exactly this when companies choose not to buy data like this to set their bands.

I super agree that fully open salary data would be amazing.

On the second point, I would argue that you have very little ability to determine when you’ve gained enough experience as an employee to argue for a raise. Whereas an employer with access to Pave has a _ton_ of ability to determine whether you have or have not. Yours is based entirely on personal experience and feel, plus maybe talking to a few coworkers. Theirs is based on aggregated data from thousands of employees

In many tech companies there is a skill matrix and competency attached to jobs, and these are tied to compensation bands. Often these skill matrices are given to employees too. When someone complains that they are not being paid fairly or that they are working at a higher level, these skill matrices are used by management to double check that the right hiring/raise decisions were made.

Mistakes get made and not all managers are the same, but believe it or not there are companies where senior management does try for consistency and fairness in how they set compensation. These companies also often have internal studies run that check for biases or oddities in compensation. E.g. which departments are above the standards, which are below, which are not progressing juniors enough. Without data all this is impossible. You can't build a fair, objective, and especially not transparent system without data.

>What level of data are they getting? If it’s tied to your HR system, does it get anonymized performance reviews?

Pave user here. Absolutely not. It's anonymised comp data. Essentially salaries and job titles only.

Whilst I do agree with your point that data like this should be publicly available, I'm not sure I understand how it gives employers a negotiation advantage?