What data must sponsors maintain regarding their Affirmative Action Programs?

Sponsors must collect and maintain information on all aspects of compliance with the EEO regulations for Registered Apprenticeship Programs, including, but not limited to:

• Selection activities (including applications, tests and test results, interview notes, bases for selection/rejection of applicants, and any other records required to be maintained under the Uniform Guidelines for Employee Selection Procedures;
• Invitations to voluntarily self-identify as an individual with a disability, for those sponsors required to develop an Affirmative Action Program;
• Information pertinent to the operation of the apprenticeship program, including but not limited to job assignments, promotion, demotion, transfer, layoff, termination, rates of pay (and other forms of compensation), conditions of work, hours of work and training, and any other personnel records relevant to EEO complaints filed with the Registration Agency or other enforcement agencies;
• Evidence that the sponsor’s equal opportunity policy has been disseminated in the workplace;
• Universal recruitment activities;
• Evidence that participatory anti-harassment training has been provided – and to whom;
• The written Affirmative Action Plan and documentation of its components, for those sponsors required to develop an Affirmative Action Program;
• Requests for reasonable accommodation; and
• Any other records pertaining to compliance with the apprenticeship EEO regulations that may be required by the Registration Agency.

Sponsors must also be able to identify the race, sex, ethnicity, and – when known – the disability status of each apprentice on whom they have records.  These records must be maintained for five years and must be made available, upon request, to the Registration Agency.

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Yes. The same record-keeping requirements apply to applicants for apprenticeship, where possible.  Each applicant must be asked to voluntarily identify their race, sex, ethnicity, and disability status.

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Any information obtained on the medical condition or history of an apprentice or applicant must be collected and maintained on separate forms and in separate medical files.  The information must be treated as a confidential medical record.  Supervisors and managers may be informed of necessary work or duty restrictions and accommodations; first aid and safety personnel may be informed, when appropriate, if an apprentice’s or applicant’s disability might require emergency treatment; and Government officials engaged in enforcing 29 C.F.R. 30, the laws administered by the Office of Federal Contract Compliance Programs, or the Americans with Disabilities Act must be provided relevant information on request.  Medical information or history obtained on apprentices or applicants may not be used for any other purposes.

Note that completed Voluntary Disability Disclosure Forms must also be kept confidential and be maintained separately from any confidential medical records for apprentices or applicants.

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