It is not unusual for companies to have all ethnicities and race in one question on survey forms used for applicants and employees. The approach that suggests companies should survey for Hispanic origin first and then ask about race is an outgrowth of revisions that were made to the federal EEO-1 report several years ago. Technically speaking, "Hispanic" is considered an ethnicity by EEOC while classifications such as "African American" or "American Indian" are considered races. It's interesting to note that OFCCP's formal regulations have never been changed to mirror EEOC's approach to race and ethnicity. OFCCP's regulations continue to suggest there are five race categories, while EEOC's EEO-1 report suggests that Hispanic is a race and that there are then six race categories to choose from for non-Hispanics. One of the reasons this is important is that EEOC does NOT have a formal requirement to collect race, ethnicity and/or gender data from applicants. Only OFCCP has such a requirement. Both EEOC and OFCCP require the collection of race and gender information from EMPLOYEES, but applicant surveys are actually instruments of OFCCP and not EEOC. The bottom line is that it there are other employers collecting race and ethnicity data by including race and ethnicity in one question, and this seems to be acceptable to EEOC and OFCCP.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.