Original Issuance Date: May 14, 1990
Last Revision Date: February 26, 2020

1. Policy Purpose

The purpose of this policy is to ensure that Affirmative Action/Equal Employment Opportunity (AA/EEO) data is collected by all UW institutions in a manner that is consistent with federally mandated definitions using a reliable collection technique.

2. Responsible UW System Officer

Senior Associate Vice President and Chief Human Resources Officer

3. Scope

This policy applies to employees of all UW System institutions.

4. Background

Data on sex/gender and racial/ethnic heritage are used to determine key reporting categories for federal, state, systemwide, and institutional reports. A procedure that ensures the collection of accurate sex/gender and racial/ethnic heritage data at the time of hire or during a later correction procedure will lessen the number of errors in the annual AA/EEO data compilations and save the time of affirmative action personnel who must identify and correct errors. Such a procedure can also be used to ensure accuracy and timeliness in the collection of the federally required data on veterans, protected veterans, and individuals with disabilities.

In addition, the completion of all Integrated Postsecondary Education Data System (IPEDS) surveys, in a timely and accurate manner is mandatory for all institutions that participate or are applicants for participation in any Federal financial assistance program authorized by Title IV of the Higher Education Act of 1965, as amended. The completion of the surveys is mandated by 20 U.S.C. § 1094(a)(17). The collection and reporting of racial/ethnic data are mandatory for all institutions that receive, are applicants for, or expect to be applicants for federal financial assistance as defined in the Department of Education (ED) regulations (34 C.F.R. § 100.13), implementing Title VI of the Civil Rights Act of 1964, or defined in any ED regulations implementing Title IX of the Education Amendments of 1972. The collection of racial/ethnic data in vocational programs is mandated by Section 421(a)(1) of the Carl D. Perkins Vocational Education Act of 1998.

5. Definitions

Definitions specific to this policy:

Sex/gender information: A term that means male or female.

Racial/ethnic heritage categories: Categories defined as according to regulations established by the federal government on collection and reporting of racial/ethnic data.

  • Hispanic or Latino: A person of Cuban, Mexican, Puerto Rican, South or Central America, or other Spanish culture or origin regardless of race.
  • American Indian or Alaska Native: A person having origins in any of the original peoples of North and South America (including Central America) who maintains cultural identification through tribal affiliation or community attachment.
  • Asian: A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian Subcontinent, including for example Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.
  • Black or African American: A person having origins in any of the black racial groups of Africa.
  • Native Hawaiian or Other Pacific Islander: A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
  • White: A person having origins in any of the original peoples of Europe, the Middle East or North Africa.
  • Two or More Races: A person having a combination of two or more of the above Racial/ ethnic heritage categories.

Veteran: Any person, who served honorably on active duty in the armed forces of the United States.

Protected Veteran: Someone who has served in the military and falls into under one or more of the four protected veteran categories: (1) disabled veterans; (2) recently separated veterans; (3) active duty wartime or campaign badge veterans; and (4) Armed Forces service medal veterans.

Person with a disability: Any person who has a physical or mental impairment that substantially limits one or more major life activities; has a record of such impairment; or is regarded as having such impairment.

6. Policy Statement

The UW System is committed to the uniform collection of the seven self-reported data elements (Hispanic or Latino, American Indian or Alaskan Native, Asian, Black or African American, Native Hawaiian or Other Pacific Islander, White and Two or More Races) for its federal, state, systemwide, and institutional reports. It is also committed to improving the accuracy of the data and the efficiency with which the collection task is accomplished. To achieve these ends UW System institutions will:

A. Designate an office or a person who will be responsible for the procedure used to collect sex/gender, racial/ethnic heritage, veteran, protected veteran, and disability data from new employees.

B. Ensure that the responsible office or person will collect the seven self-reported data elements according to the federally mandated definitions identified in this document. Employees should also be advised of the following:

  1. providing this information is optional;
  2. failure to submit the information will not in any way affect their present or future employment;
  3. the information will remain confidential and shared only on an authorized, need-to-know basis with selected personnel, at the institution or system level;
  4. the information will be used for affirmative action purposes, primarily mandated aggregate reporting; and
  5. if they do not provide the racial/ethnic heritage information, federal regulations stipulate that a visual survey or post-employment records may be used to acquire racial/ethnic heritage information necessary for the completion of affirmative action report.

C. Specify the procedure the responsible office or person will use to collect and input these data into the UW System payroll files or other data files as selected by the institution.

D. Assign an office or a person who will interact with affirmative action/equal employment opportunity personnel in the correction of sex/gender, racial/ethnic heritage, veteran, and disability data when necessary.

7. Related Documents

20 U.S.C. § 1094(a)(17) – Program Participation Agreements
34 C.F.R. § 100.13 – Nondiscrimination under Programs Receiving Federal Assistance
38 U.S.C. § 101(2) – Definition of Veteran
41 C.F.R § 60-741.41 – Availability of Affirmative Action Program
42 U.S.C. § 12102(1) – Definition of Disability
48 CFR § 22.1301 and 38 U.S.C. § 4212(3)(A)) – Definition of Protected Veteran and Covered Veteran
Directive No. 15, Race and Ethnic Standards for Federal Statistics and Administrative Reporting. (Directive No. 15 supersedes section 7(h) and Exhibit F of OMB Circular No. A-46 dated May 3, 1974 and as revised May 12, 1977.) U.S. Department of Education, Office of Civil Rights, Region V.
Integrated Postsecondary Education Data System
Racial Ethnic Reporting through IPEDS
Section 421(a)(1) of the Carl D. Perkins Vocational Education Act of 1998
Title IV of the Higher Education Act of 1965
Title VI of the Civil Rights Act of 1964
Title IX of the Education Amendments of 1972
UW Regent Policy Document 17-4, Equal Employment Opportunities

8. Policy History

Revision 1: February 26, 2020
First Approved: May 14, 1990

9. Scheduled Review

February 2025