In an audit, it is imperative that the Affirmative Action Plan and support data be as complete as possible. According to the rules and regulations enforced by the OFCCP, a lack of data can be a real problem for any company. I suggest you take a look at availability data as well to identify problem areas - this is what the agency typically looks at in an absence of data. You may want to seek assistance from a professional that has tackled this type of issue before. Remember that any conversations with a compliance officer may bind your company to statements. Good luck in your audit.