Gathering EEO data after the fact

Soho · May 2002

I work for a small manufacturing company in California, under 100 employees. Because we have just signed a contract that involves creating a product for a federal contractor, we are now classified as a federal subcontractor. Up until this point, I had never filed EEO-1 since the company size was under 100 employees. I now am in the process of gathering the data required for filing. The company has never formally gathered EEO information in regards to ethnicity. Normally a job applicant is asked to submit this information voluntarily along with his application. The company never asked for this information even though they have an equal employment opportunity policy. Can I ask the current employee group to voluntarily submit this information,after the fact,for EEO-1 reporting purposes or do I just estimate to the best of my knowledge the ethnicity of the current work force?

Miriam George · May 2002

I went through a similar scenario with a former employer. We were advised by EEO officers that we should ask our employees to voluntarily submit the information (we developed a form just for that), but in cases where they refused or even strongly preferred not to, I was to guess at what I thought their race to be and put that on the form. We wound up having 100% voluntary submission of the information once our employees knew the reason for the request.

Gillian · May 2002

I'm also in California. Miriam's response is right on. The reason that you want the data to come from the employees is that your data will become the base from which you will work from now on. If you guess you will always be wondering if you guessed right and if you are audited on your affirmative action plan at some point it won't be a good idea to tell the compliance officer that you guessed at everything.

Soho · May 2002

Thank you for the information. It confirms the action I would like to take on this and prevent problems down the road.

Gathering EEO data after the fact

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