*The U.S. Equal Employment Opportunity Commission*

----

# Guidelines for Ensuring and Maximizing the Quality,    Objectivity, Utility, and Integrity of Information Disseminated    by the U.S. Equal Employment Opportunity Commission.

-  Scope and Applicability of the        Guidelines. The Guidelines for Ensuring and        Maximizing the Quality, Objectivity, Utility, and Integrity        of Information Disseminated by the U.S. Equal Employment        Opportunity Commission (EEOC's Guidelines for Ensuring        Information Quality)  establish an approach to ensure        that EEOC achieves quality in the information it        disseminates to the public on or after October 1, 2002. The        information quality standards described in the Office of        Management and Budget's final guidelines (issued February        22, 2002, 67 FR 8452) are incorporated by reference.            -             There are several important concepts in the guidelines            that address the type of products covered and the            mechanisms for providing these products to the public.            Two of those parameters are:                  - *Information*  means any              communication or representation of knowledge such as              facts or data, in any medium or form, including              textual, numerical, graphic, cartographic, narrative,              or audiovisual forms.
    - *Dissemination*  means              agency initiated or sponsored distribution of              information to the public. 
  - These guidelines apply to certain information          disseminated by the EEOC on or after October 1, 2002,          regardless of when the information was first          disseminated. Also, these guidelines apply to information          EEOC generates, and to information that other parties          provide to the EEOC that the EEOC relies upon or          disseminates. Information provided by other parties and          relied upon or disseminated by the EEOC are subject to          these guidelines.
  -             Examples of information prepared by or for the EEOC            subject to the  EEOC's Guidelines for Ensuring            Information Quality include:                  - Information prepared for public              dissemination.
    - Reports, studies and summaries prepared to inform              the public about the impact of the EEOC's programs              or, to use in formulating broad program policy.
    - Aggregated information on administrative and              litigation processes. 
  - These guidelines do not apply to all information          disseminated by the EEOC. The fact that an information          product disseminated by EEOC before October 1, 2002, is          still maintained by the EEOC as an archival record in          files, distributed publications and in other ways does          not make the information automatically subject to these          guidelines or to the request- for-correction          process.
  -             Examples of information generally NOT covered by these            guidelines include:                  - Information collected or developed by the EEOC              that is not disseminated to the public, including              documents intended only for inter-agency or              intra-agency communications.
    - Information collected in or relating to the              EEOC's administrative and adjudicative processing of              charges in the private sector and of complaints in              hearings and appeals in the federal sector. This              includes information provided for subpoenas,              findings, decisions, settlements, orders, opinions,              or amicus and other briefs. These are excluded              because there are well-established procedural              safeguards and rights in the statutes and regulations              enforced by the EEOC.
    - Information pertaining to basic agency              operations, such as procedural, operational, policy,              and internal manuals prepared for the management and              operations of EEOC that are not intended for public              dissemination.
    - Management information that is produced and              intended primarily for internal use.
    - Internal information limited to government              employees or agency contractors.
    - Responses to requests for information under the              Freedom of Information Act, the Privacy Act, the              Federal Advisory Committee Act or other similar              law.
    - Research reports or studies prepared by other              individuals, groups or organizations, unless the EEOC              has directed an individual, group or organization to              disseminate the information or the EEOC retains the              authority to review and approve the information              before release.
    - Correspondence with individuals or persons.
    - Archival records.
    - Public filings by non-EEOC parties, unless the              information is used or disseminated by the EEOC.
    - Press releases announcing or describing recent              events or EEOC enforcement actions; and press              releases, fact sheets, press conferences or similar              communications in any medium that announce, support              the announcement or give public notice of information              EEOC has disseminated elsewhere.
    - Information presented to Congress and included              under item #2, above, and other information presented              to Congress, unless it is new, substantive              information not previously disseminated to the public              by the EEOC.
    - Hyperlinks to information that the EEOC itself              does not disseminate.
    - Views or opinions by others, as long as the EEOC              makes it clear that the opinion is not the agency's              point of view.
    - Program publications that explain how to file an              EEO complaint, such as that contained in              pamphlets. 
-  Standards for Information Quality.         "Quality" is a statutory term that collectively comprises        the terms of utility, objectivity, and integrity. Each        aspect of quality is set forth in the definitions of these        three terms. The EEOC will ensure and establish a basic        standard of quality for all EEOC information prior to        dissemination to the public. Also, the EEOC will review the        quality of information before it is disseminated to the        public, and treat information quality as integral to every        step of its development of information, including creation,        collection, maintenance and dissemination.            -  Utility.  Utility refers to the            usefulness of the information to its intended users,            including the public. The EEOC will consider the use of            its information from the user's perspective to produce            useful, policy-relevant information.                  -  The EEOC will keep informed of information                needs through active and ongoing contact with the                user community and will provide vehicles for user                input.  The EEOC keeps abreast of information needs with                respect to the analysis of its programs in a                variety of ways. It performs internal analyses of                information requirements; convenes and attends                conferences; works with advisory committees,                community-based organizations and stakeholder                groups; and seeks input through a variety of                outreach activities it sponsors. In addition,                contact information is now included with some of                the EEOC's information products, and will be made                more available in the future on a variety of                information products, where appropriate, to allow                for questions, comments, and suggestions from                users. 
    -  The EEOC's analytical and statistical                publications and other information products will be                reviewed to ensure that they remain relevant and                timely to address current information                needs.  The content of ongoing information products is                changed, new products are introduced, and some                products are discontinued based on internal product                reviews, information from users, and the changing                needs and emphasis from proposed changes in the law                and related policy debates. The EEOC identifies                requirements to support the preparation of                analytical reports and policy studies and modifies                its current information products accordingly. 
    -  The EEOC's information dissemination                process will make information products widely                available and broadly accessible.  Most public reports and other data products are                available in print, and more are becoming                electronically available. All documents posted on                our Web site are in compliance with Sections 504                and 508 of the Rehabilitation Act of 1973, as                amended, to ensure the accessibility to individuals                with disabilities, specifically an audience that                includes persons who have a visual impairment and                read on- line using assistive technology. 
    -  The EEOC will demonstrate, in any clearance                requests submitted under the Paperwork Reduction                Act, the utility for collecting information from                the public that the agency plans to                disseminate.  The EEOC provides, in its clearance packages                under the Paperwork Reduction Act, information on                the utility of equal employment opportunity data                gathered from private employers, unions, state and                local entities and schools. This information will                be collected, maintained, and used in a way                consistent with the agency's guidelines. 
  -  Objectivity.  Objectivity involves two            specific elements: presentation and substance.            Disseminated information should be presented in an            accurate, clear, complete and unbiased way. This            involves presenting information in the proper context.            In addition to the presentation of information,            objectivity ensures the substance of products is            accurate, reliable and unbiased. Basically, objectivity            is ensured if reliable data sources and sound            analytical techniques are used; methods exist to            carefully review the contents of all information            products; and information is prepared by qualified            people using proven methods.                  -  *Information products disseminated by                the EEOC will be based on reliable, accurate                data.*  Much of the information disseminated by the EEOC                is based on its enforcement data files. Those files                contain information used to manage programs. The                EEOC conducts on-going quality assurance reviews of                employment discrimination charges and settlement                information in its data systems to ensure their                accuracy. EEOC has a comprehensive data                verification process in place involving coordinated                efforts between headquarters, field office staff                and managers to detect and correct data anomalies,                outliers and missing information in its charge and                complaint databases. This process combines direct                staff review of data with computer programs and                automated edit checks that generate data integrity                reports. Also, statistical reports are validated on                an on-going basis and quality assurance assessments                of the reports are prepared for management on a                quarterly basis. Headquarters program offices                conduct reviews of files, including onsite reviews,                and check for the quality and accuracy of database                information, where appropriate.  The EEOC has deployed new personnel, payroll,                and financial management systems. The financial                system conforms to high standards of financial                accountability to provide complete, reliable,                consistent, timely, and useful management                information to enable the agency to carry out its                fiduciary responsibilities.  The EEOC also uses data from external sources                for some of its information products. Equal                Employment Opportunity (EEO) data is collected by                the EEOC from private sector employers, labor                organizations, state and local governments, and                elementary and secondary public schools. The                Department of Education collects information from                institutions of higher learning and share this data                with the EEOC. The information is collected on a                regular, recurring schedule using a magnetic medium                for example, interactive diskettes or computer                tapes or on paper forms that are converted to a                magnetic medium. EEO data is also collected from                federal agencies. A web-based data collection                mechanism, implemented in fiscal year 2002, allows                government agencies to electronically transmit                their aggregate EEO data to EEOC.  Data on paper forms are manually edited before                keying onto a magnetic medium. The collection of                data using magnetic or electronic media increases                its accuracy by eliminating any potential errors                that could result from manual re-keying. All of the                information on magnetic or electronic media goes                through various data checks to ensure consistency                and accuracy. As one example, employer information                is compared year-to-year for data anomalies or                outliers. 
    -  *All data used in the preparation of                information products will be compiled using                statistically sound procedures implemented by                qualified professional staff.*  Enforcement data files used to prepare                disseminated information products are compiled and                analyzed by qualified professional staff. Data                verification checks are conducted using manual and                automatic procedures to assist in validating the                accuracy and the internal consistency of the                information. Professional staff peruse the                information manually for anomalies and outlier data                and make corrections to further ensure the accuracy                of the information. 
    -  *Analytic reports will be prepared using                sound statistical and analytic methods and by staff                knowledgeable about the data sources and models                used.*  Reports are prepared by staff using a variety of                analytical techniques ranging from simple                tabulations and descriptive summary statistics to                other statistical methods and models. Staff                preparing analytic reports and policy studies are                expert in their use of relevant enforcement data                files, external data sources, and the statistical                approaches used to provide the data and                analysis 
    -  *Analytical techniques will be reviewed                to ensure that they are appropriate for the data                and the analysis to which they are                applied.*  All analytical reports and policy studies are                reviewed by qualified staff to ensure that the                analysis is valid, complete, unbiased, objective,                and relevant. Analytic techniques are clearly                described in relevant reports and data sources are                identified in publications. When analyses are based                on projections, the assumptions used to produce the                projections are identified. 
    -  *Data sources and other relevant                disclosure information will be documented in                publications, either for the publication as a whole                or for individual tables.*  Documentation in publications contains                information on data sources, including definitions                and specifications of variables. Report                documentation also includes, where appropriate,                information on sampling and any disclosure rules or                techniques. 
    -  *All information products will be edited                and proofread before release to ensure clarity and                coherence of the final report, or Website                posting.*  Text is edited to ensure that a report is easy                to read and grammatically correct; thoughts and                arguments flow logically; and, information is                worded concisely and lucidly. Tables and charts are                edited to ensure that they clearly and accurately                illustrate and support points made in the text and                include concise and descriptive titles. Tables and                charts indicate the unit of measure and the                universe being examined, and all internal labels                (column headings, row stubs, and panel headings)                accurately describe the information they                contain. 
    -  Influential Information and                Reproducibility.  An enhanced level of                objectivity is required for "influential                scientific, financial or statistical information."                "Influential" information means that the agency can                reasonably determine that dissemination of the                information will have or does have a clear and                substantial impact on important public policies or                important private sector decisions. Information                defined as "influential" has an added level of                scrutiny afforded it, to include the need to ensure                it is reproducible.                  The EEOC will first determine whether or not the                information is influential to determine whether it                is covered under this portion of the guidelines.                The "influential" designation will be applied to                information disseminated by EEOC sparingly, if at                all. Several aspects will be considered:        - To the degree that any of EEOC's information                  may be covered by this aspect of the guidelines,                  "influential" information only pertains to                  statistical information.
      - For EEOC, influential statistical information                  is only that information expected to have a clear                  and substantial impact on the national level and                  on major public and private policy decisions                  related to federal equal employment opportunity                  issues.
      - A clear and substantial impact is one that                  EEOC is firmly convinced is at a greater level                  than would ordinarily be the case; that the                  impact has a high probability of occurring. If it                  is merely speculative or arguable that an impact                  will occur, or if it is a close judgement call,                  then the impact is probably not clear and                  substantial.
      - The impact must be on important public policy                  or private sector decisions that are expected to                  occur. Even if information has a clear and                  substantial impact, it is not influential if the                  impact is not on a public or private decision                  that is important to policy or other                  decisions.
      - It should be noted, however, that the                  influential definition applies to the                  "information" itself. Information may support a                  very important decision or action taken by EEOC.                  It can not be inferred, however, that the                  information automatically can be assumed to be                  "influential" and covered under this section of                  the guidelines.
      -                     Only if the information is determined to be                    "influential" will EEOC address several other                    aspects for dissemination of the information to                    the public:                      (1) If the statistical information is                    influential, the EEOC generally will ensure                    that the information contains a high degree of                    transparency about the data and methods used in                    order to facilitate the reproducibility of this                    information by qualified individuals or                    groups.  (2) Influential statistical information can                    include original and supporting data or                    analytic results.  (3) With regard to original and supporting                    data, EEOC guidelines do not require that all                    disseminated data be subjected to a                    reproducibility and transparency requirement,                    because some information may not be publically                    accessible due to confidentiality protections                    or other compelling reasons.  (4) With regard to analytic results, if the                    data is identified as influential and can be                    made available publically, EEOC will provide                    sufficient transparency about the data and the                    methods used to analyze it to enable an                    independent analysis by a qualified individual                    or group. Where the data can not be publically                    disclosed, the EEOC will use rigorous                    statistical checks on its analytic results,                    document the checks undertaken, and disclose                    the specific data sources, quantitative                    methods, and assumptions used.  (5) The EEOC does not have "influential"                    information that involves risks to human                    health, safety and the environment, based on                    the Safe Drinking Water Act Amendments of 1996                    (42 U.S.C. 300g-1(b)(3)(A) & (B)).                    Consequently, the quality principles                    articulated in the Act for "risk" information                    do not apply to the EEOC. 
  -  Integrity.  Integrity refers to the            security of information protection of the information            from unauthorized access or revision, to ensure that            the information is not compromised through corruption            or falsification.                  -  *The EEOC will employ rigorous controls                that represent sound security practices to ensure                the integrity of the information it                disseminates.*  The EEOC has programs and policies for securing                its resources as required by the Computer Security                Act of 1987 (P.L.100-235), Office of Management and                Budget Circular A-130, and the Government                Information Security Reform Act (P.L. 106-398,                title X, subtitle G). These security procedures                address all major components of information                security and apply to all operating components. In                addition, the EEOC is subject to statutory                requirements to protect the sensitive information                it gathers and maintains on individuals.                Requirements regarding that information are                contained in the following statutes or guidance                documents:        - Privacy Act of 1974
      - Computer Security Act of 1987
      - Office of Management and Budget (OMB)                  Circulars A-123, A-127, and A-130
      - Government Information Security Reform                  Act
      - Federal Managers' Financial Integrity Act                  (FMFIA) of 1982
      - Sections 706(b) and 709(e) of Title VII of                  the Civil Rights Act of 1964, 42 U.S.C.                  ..2000e-5(b) and 8(e).  In addition to adhering to these requirements,                access to information and the underlying data bases                are restricted in the system to ensure the                integrity of the information and its appropriate                utilization. 
-  Procedure to Seek Correction of Information Covered        Under the EEOC's Guidelines for Ensuring Information        Quality.  The EEOC has created an area on        its Web site at  www.eeoc.gov  containing         EEOC's Guidelines for Ensuring Information        Quality  and other relevant information, including        the procedures for requesting correction to agency        information subject to these guidelines.          Using the following procedures, persons affected by the        EEOC's disseminated information can request correction of        the information that does not comport with EEOC's or OMB's        information quality guidelines. Affected persons can        request correction of information first disseminated on or        after October 1, 2002, and information previously created        by the EEOC which is newly disseminated on or after October        1, 2002. The EEOC's information disseminated only before        October 1, 2002, is not covered by the EEOC's        Guidelines for Ensuring Information Quality.  Also, there are some circumstances in which there is an        existing process to respond to concerns expressed about        EEOC's information. The OMB guidelines encourage agencies        to make use of existing processes in a flexible way,        tailored to their programs. When there is a sound existing        process, such as a process that provides opportunities for        public participation in making an agency decision, the EEOC        will not duplicate the process with a separate        request-response mechanism. The substantive standards of        quality, the information quality standards provided in the        OMB and EEOC guidelines, remain applicable to any such        dissemination of information.  In addition, the EEOC may disseminate a study, analysis,        or other information prior to taking a final action based        on this material or prior to releasing a complete        information product. The EEOC will consider requests for        correction of the study, analysis or other information        product before it takes its final action or releases the        final informational product if it determines that an        earlier response will not unduly delay the issuance of the        final action or the information product; and, the        person requesting the correction shows that there is a        reasonable likelihood that he/she will suffer actual harm        from the disseminated information if the request is not        resolved before the final action is taken or the final        product disseminated.  **Important Note:** Do not submit        any information, comments or data relating to a charge of        discrimination that may have been filed with the agency.        This is not a procedure for processing any charge-specific        information in the private sector or hearings or appeals in        the federal sector. Anything submitted for that purpose        will not be considered for the purposes of these        guidelines. If you want to discuss charge, hearings or        appeals information, please contact the appropriate field        office nearest you. Our offices are listed on the agency's        web site (www.eeoc.gov).        You can also call 1-800-669-4000 (TTY: 1-800-669-6820) to        be automatically connected to the closest EEOC office.    -  What you must do.  The U.S. Equal            Employment Opportunity Commission has developed a            procedure to allow you to seek correction of            information disseminated by the EEOC. Submit your            request in any of the following ways:                  -                 U.S. Postal Service or Other Delivery Service                  Send your request to:  Request to Correct EEOC Published                Information                 U.S. Equal Employment Opportunity Commission                 Office of Research, Information and Planning                 Room 8219                 1801 L Street, N.W.                 Washington, D.C. 20507 
    -                 Facsimile                  Use a cover sheet on top of your request, and                indicate the fax is for:  Request to Correct EEOC Published                Information                 U.S. Equal Employment Opportunity Commission                 Office of Research, Information and Planning                 Room 8219  Fax to: (202)663-4093 
    -                 E-Mail                  Send requests by e-mail to:[email protected] 
    - If you have any questions, please mail, fax or              e-mail your name, telephone number, and hours you can              be reached (including the time zone). An EEOC              representative will contact you.
    -                 What information to include in your request for a                correction in EEOC information:                        - Provide your name, mailing address, fax                  number, e-mail address, telephone number and                  organizational affiliation, if appropriate. We                  need this information to respond to your request                  and contact you, if necessary.
      - Indicate that your request for correction of                  EEOC disseminated information is submitted under                  the procedures of the  Guidelines for                  Ensuring and Maximizing the Quality, Objectivity,                  Utility, and Integrity of Information                  Disseminated by Federal Agencies.
      - Clearly describe the information you believe                  needs to be corrected. Include the name of the                  report or data product where the information is                  located, the date of issuance, and a detailed                  description of the information to be corrected.                  State specifically  why  the information                  should be corrected; that is, describe in what                  way and why the information is  incorrect .                  If possible, recommend specifically  how                   the information should be corrected. Provide                  supporting documentary evidence, such as                  comparable data or research results on the same                  topic, to help in the EEOC's review of your                  request.
      - Describe how you are affected, or harmed, by                  the information error in the report or data                  product. 
    - It is important to be specific in your request              for a correction. Also, it is critical to provide all              of the information requested. Without all of the              items of information, the EEOC may be unable to              process your request in a timely manner, or provide a              response to the issue(s) you raise. 
  -  What we will do.      - We will review your request and determine whether              a correction is warranted, and, if so, what action to              take. Some of the factors in that determination are              the nature, influence, and timeliness of the              information involved; the significance of the              correction on the use of the information; and, the              magnitude of the correction needed.
    - We will respond to you by letter, e-mail, or fax              usually within 60 calendar days from the date we              receive your request. Some situations may require              additional time or information from you. Our response              will explain the findings of our review and the              actions the EEOC will take. If the EEOC agrees with              the correction, it will take steps to notify the              public of its decision by withdrawing the information              in question from the public domain.
    - EEOC may choose not to respond to requests for              corrections that are frivolous or unlikely to have              substantial future impact. In addition, it may not be              in the public interest for the EEOC to devote              significant resources to correcting information where              the expenditure of the resources is not, in EEOC's              view, cost effective in light of the significance of              the asserted error, the benefits that are likely to              be derived from any correction, the costs of the              correction, and the EEOC's more pressing priorities              and obligations. 
  -  Your right to appeal our decision.  If            we deny your request for a correction of the            information, you can administratively appeal our            decision.                  - You will be told at the time of a denial how to              appeal.
    - If an appeal is requested, the office who handled              the original request for correction will not have the              responsibility for resolving the appeal.
    - We will respond to you by letter, e-mail, or fax              usually within 60 calendar days from the date we              receive your appeal. Some situations may require              additional time. Our response will explain the              findings of our review and the actions the EEOC will              take. If the EEOC agrees with the correction, it will              take steps to notify the public of its decision by              withdrawing the information in question from the              public domain. 

----

*This page was last modified on September 30,    2002.*

Return to Home    Page