How do I complete step 5?

Step 5: Set Up Ongoing Recordkeeping in Your Program

Please click here to open the Program Registration and Apprenticeship Agreement form.

Categories that this form captures are:

• Sex
• Race:
  • White
  • African American
  • Asian
  • Native American / Alaska Native
  • Native Hawaiian / Pacific Islander
• Ethnicity:
  
  • Hispanic/Latinx
  • Non-Hispanic/Latinx
• Disability (when known):
  • Identifies as having a disability
  • Does not identify as having a disability

Apprentices’ self-identifications are the preferred method for identifying their race, sex, ethnicity, and disability status, and you may take that data from their selections on the 671 form.

However, you may find that not all applicants complete these questions on the 671 form—completing them is voluntary. If an apprentice does not designate their sex, race, or ethnicity on this form, you may use visual observation to identify their demographic data. But don’t guess or assume—if you’re not sure, just consider the information “unknown.”

Similarly, where an apprentice or applicant does not complete the Voluntary Disability Disclosure form, or indicates that they “don’t wish to answer” it, you may:

• Use visual observation to identify obvious disabilities
• Rely on the disclosures that the apprentice or applicant made to request a reasonable accommodation
  

In the absence of any of the above, consider the individual's disability status to be “unknown.”

Applicants’ protected-class identification

Identifying the protected classes of applicants is more difficult, because there is no governmental form for identifying race, sex, and ethnicity that applicants must fill out. Applicants are invited to fill out the Voluntary Disability Disclosure form, which is a tear-off addendum to Section II of ETA form 671, so there is a source of self-identification information for disability status.

You may ask applicants to designate their race, sex, and ethnicity on their application form if you are asking in order to track the demographics of your applicant flow. In fact, the Apprenticeship EEO regulation on sponsor identification of record encourages you to do this.

But if you do request race, sex, and ethnicity information on the application form, it is crucial to guard against discriminatory selection by using a mechanism such as a "tear-off" sheet to separate this information from the information used to decide whether to admit the applicant to your program. Otherwise, obtain applicants’ sex, race, or ethnicity data by visual observation (again, keeping the information separate from the information used for admission decisions; and again, don’t guess).

Additional tips about record keeping:

• Records must be kept for 5 years
• Medical information must be:
  • Kept separately
  • Treated as confidential medical records (following HIPAA guidelines)
• Records must be provided to the registration agency:
  • On request
  • With on-site access for EEO compliance reviews and complaint investigations

Your next step

At the end of each of the five steps, we will ask you to record your next step using prompts from the course expert. Why? So you can walk away from this course with tangible things you need to do next. You can either record your answers for step 5:

• In this Road Map,
• Right within Canvas by clicking TAKE THE SURVEY,
• Or both!