Joint Trades Comments to EEOC re: Information Collection

The undersigned representatives of employers are responding to the Equal Employment Opportunity Commission’s (“EEOC” or “the Commission”) request for public comments contained in the 2019 Notice of Information Collection (“2019 Notice”) pursuant to the Paperwork Reduction Act (PRA). In particular, these employer representatives wish to express support for EEOC’s decision to not seek renewal of OMB clearance for the EEO-1 Component 2 form and to request a new OMB clearance number to be associated specifically with EEO-1 Component 1.

The Component 2 collection requires employers with 100 of more employees to complete and submit a form with 3,660 data fields for each of the employer’s locations encompassing pay and hours worked data on all employees broken out by EEOC-defined job classifications and income bands. By contrast, the Component 1 collection requires employers to complete and submit, for each employer location, a form comprised of only 180 data points on the gender, race, and ethnicity of employees at that location.

The employer representatives agree with EEOC’s decision to discontinue collection of Component 2 data, based on its conclusion that the degree of utility does not justify the burden imposed. The employer representatives also believe the sensitive nature of Component 2 data warrants heightened attention to protecting its confidentiality and that EEOC has not developed and confirmed adequate procedures to ensure the confidentiality of the data required to be submitted, especially if EEOC shares this data with other agencies and interested parties.

American Bankers Association
Associated Builders and Contractors
Associated General Contractors of America
HR Policy Association
National Federation of Independent Business
National Retail Federation
Society for Human Resource Management
U.S. Chamber of Commerce