Earlier in the year, I wrote an article for The OFCCP Digest about the requirements that the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has regarding the surveying of applicants and employees for demographic information. Since that time, the Department of Labor has released additional information that affects the surveying that is required of federal contractors and subcontractors. In light of the importance of understanding OFCCP’s surveying requirements and the level of confusion that has been created by the release of new information, I thought it might be helpful to revisit this topic.
Before going any further, a caveat and a note about nomenclature. Here’s the caveat: the information in this article is accurate as of November 10, 2014. It is possible OFCCP will