On Aug. 19, the Office of Federal Contract Compliance Programs published a to inform federal contractors of a request that seeks .听According to the OFCCP, submitted the FOIA request. Contractors have until Sept. 19 to submit written objections to the disclosure of their EEO-1 reports.

According to the OFCCP , 鈥淭he听provides specific instructions and听that should be addressed by those contractors who wish to object to the disclosure of their Type 2 Consolidated EEO-1 Report data.鈥� We recommend that contractors review the questions outlined in the OFCCP鈥檚 FAQs, specifically No. 10:

10. What information should contractors include in a written objection if their company decides to file one?

Contractors should include the first and last name of their company鈥檚 point of contact (POC), the POC鈥檚 phone number and email address, the company鈥檚 name and address and the parent company鈥檚 EEO-1 unit number.

Contractors should also provide as much information as possible addressing why they believe their Type 2 EEO-1 Report data should not be released under FOIA, including whether the information is commercial/financial and confidential. At a minimum, OFCCP suggests that written objections address the following questions:

• Do you consider information from your EEO-1 Report to be a trade secret or commercial information? If yes, please explain why.
• Do you customarily keep the requested information private or closely held? If yes, please explain what steps have been taken to protect data contained in your reports, and to whom it has been disclosed?
• Do you contend that the government provided an express or implied assurance of confidentiality? If yes, please explain. If no, skip to the next question.
• If you answered 鈥渘o鈥� to the previous question, were there expressed or implied indications at the time the information was submitted that the government would publicly disclose the information? If yes, please explain.
• Do you believe that disclosure of this information could cause harm to an interest protected by Exemption 4 (such as by causing genuine harm to your economic or business interests)? If yes, please explain.

If you plan to submit a written objection and require further assistance from 老牛影视National, please contact Karen Livingston at [email protected].

Learn how to submit the written objection by , or . Note: The OFCCP strongly encourages contractors to use the web form due to the volume of responses the OFCCP expects to receive.

Additional resources:

• 老牛影视general counsel Littler Mendelson鈥檚 analysis: