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Is PER_ACTION_OCCURRENCES.CREATED_BY reliable for identifying the initiator?

Summary:

We use PER_ACTION_OCCURRENCES in our HCM reporting to identify who initiated an assignment transaction (Employee, Manager or HR). Historically, CREATED_BY has been reliable for this purpose, but we are now seeing cases where it reflects the last approver/HR Admin rather than the person who originally submitted the transaction.

We have a Completed Transactions report that identifies changes to HCM data and whether the change was initiated by the Employee, Manager or HR. The report is used for self-service adoption reporting and auditing.

For most areas, we query the underlying HCM data tables directly rather than relying on the transaction tables. This is intentional, as it allows us to:

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