EEOC Publishes Revised EEO-1 Component 2 Report

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EEOC’s Pay Data Grab a New Reality

Starting March 2018, the EEOC put in place the new EEO-1 Report.  The agency has encountered tremendous push back from Senators and corporations across the country that have provided testimony and voiced concerns regarding how EEOC will use and protect the data collected. 

EEOC has failed to satisfy and alleviate the employer’s concerns.   

The EEOC has also shown total disregard for the results of the National Research Council’s study “Collecting Compensation Data From Employers,” a commissioned study that the EEOC requested following a recommendation from a White House Task Force. 

The results of this study recommend that EEOC address the following:

  • have a clear plan on how the data will be used
  • how to test the quality of the data
  • how it will be used to identify unlawful pay discrimination
  • the burden that will be placed on respondents
  • how the data will be protected from cyber attacks
  • protecting the data from freedom of information act requests

The EEOC has ignored the recommendations and concerns from the National Research Council’s study, and they have also ignored their responsibilities under the Paperwork Reduction Act.

Respondents have no clear guidance on how the EEOC’s collection of pay data will be used or how pay data is protected. 

CRI recommends that employers begin preparing for the March 31, 2018, EEO-1 report submission by creating an action plan that will start with IT staff, payroll system vendors, and HRIS vendors to ensure that the gathering of data between systems can be reconciled. 

Employers should also budget for additional staff and resources to provide a system is in place and that funds are allocated to assess risk by conducting pay analyses.

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