Operational Policy: EEO 1
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The University of Wisconsin System
UPS OPERATIONAL POLICY: EEO 1
SUBJECT: Affirmative Action Data
_____________________________________________________________________________________
Original Issuance Date: July 1, 2015
Last Revision Date:
1. POLICY PURPOSE:
The purpose of this policy is to ensure that Affirmative Action/Equal Employment Opportunity
(AA/EEO) data is collected by all UW institutions in a manner that is consistent with federally
mandated definitions using a reliable collection technique.
2. POLICY BACKGROUND:
Data on sex/gender and racial/ethnic heritage are used to determine key reporting categories for
federal, state, systemwide and institutional reports. A procedure that ensures the collection of
accurate sex/gender and racial/ethnic heritage data at the time of hire or during a later correction
procedure will lessen the number of errors in the annual AA/EEO data compilations and save the time
of affirmative action personnel who must identify and correct errors. Such a procedure can also be
used to ensure accuracy and timeliness in the collection of the federally required data on veterans and
individuals with disabilities.
In addition, the completion of all Integrated Postsecondary Education Data System (also known as
EEO-1) surveys, in a timely and accurate manner is mandatory for all institutions that participate or
are applicants for participation in any Federal financial assistance program authorized by
Title IV of
the Higher Education Act of 1965, as amended. The completion of the surveys is mandated by 20
U.S.C. § 1094(a)(17). The collection and reporting of racial/ethnic data are mandatory for all
institutions that receive, are applicants for, or expect to be applicants for federal financial assistance
as defined in the Department of Education (ED) regulations (
34 C.F.R. § 100.13), implementing Title
VI of the Civil Rights Act of 1964, or defined in any ED regulations implementing Title IX of the
Education Amendments of 1972. The collection of racial/ethnic data in vocational programs is
mandated by Section 421(a)(1) of the Carl D. Perkins Vocational Education Act of 1998.
3. POLICY DEFINITIONS:
Please see UPS Operational Policy GEN 0: General Terms and Definitions
for a list of general terms
and definitions.
Definitions specific to this policy:
“Sex/gender information” means male or female.
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“Racial/ethnic heritage categories” are defined as according to regulations established by the federal
government on collection and reporting of racial/ethnic data:
Hispanic or Latino: A person of Cuban, Mexican, Puerto Rican, South or Central America, or other
Spanish culture or origin regardless of race.
American Indian or Alaska Native: A person having origins in any of the original peoples of North
and South America (including Central America) who maintains cultural identification through tribal
affiliation or community attachment.
Asian: A person having origins in any of the original peoples of the Far East, Southeast Asia, or the
Indian Subcontinent, including for example Cambodia, China, India, Japan, Korea, Malaysia,
Pakistan, the Philippine Islands, Thailand, and Vietnam.
Black or African American: A person having origins in any of the black racial groups of Africa.
Native American or Other Pacific Islander: A person having origins in any of the original peoples of
Hawaii, Guam, Samoa, or other Pacific Islands.
White: A person having origins in any of the original peoples of Europe, the Middle East or North
Africa.
Two or More Races
A “veteran” is any person, who served honorably on active duty in the armed forces of the United
States.
A “person with a disability” is any person who has a physical or mental impairment that substantially
limits one or more major life activities; has a record of such impairment; or is regarded as having
such impairment.
4. POLICY:
The UW System is committed to the uniform collection of the seven self-reported data elements
(Hispanic or Latino, American Indian or Alaska Native, Asian, Black or African American, Native
American or Other Pacific Islander, White and Two or More Races) for its federal, state, systemwide
and institutional reports. It is also committed to improving the accuracy of the data and the efficiency
with which the collection task is accomplished. To achieve these ends UW System institutions will:
A. Designate an office or a person who will be responsible for the procedure used to collect
sex/gender, racial/ethnic heritage, veteran, protected veteran, and disability/handicap data from
new employees.
B. Ensure that the responsible office or person will collect the seven self-reported data elements
according to the federally mandated definitions identified in this document. Employees should
also be advised of the following:
1. providing this information is optional;
2. failure to submit the information will not in any way affect their present or future
employment;
3. the information will remain confidential and shared only on an authorized, need-to-know
basis with selected personnel, at the institution or system level;
4. the information will be used for affirmative action purposes, primarily mandated aggregate
reporting; and
5. if they do not provide the racial/ethnic heritage information, federal regulations stipulate
that a visual survey or post-employment records may be used to acquire racial/ethnic
heritage information necessary for the completion of affirmative action reports.
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C. Specify the procedure the responsible office or person will use to collect and input these data into
the UW System payroll files or other data files as selected by the institution.
D. Assign an office or a person who will interact with affirmative action/equal employment
opportunity personnel in the correction of sex/gender, racial/ethnic heritage, veteran, and
disability/handicap data when necessary.
5. RELATED DOCUMENTS:
Integrated Postsecondary Education Data System
UW System Administrative Policy 220 (formerly G41) Affirmative Action Data Collection
UW Regent Policy Document 17-4 Equal Employment Opportunities
Racial Ethnic Reporting through IPEDS
6. POLICY HISTORY:
