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The OFCCP wants more data. The agency's current proposal for all of this additional data has been described by some as both "burdensome" and "stealthy". In fact, McGuire Woods went so far as to say that the OFCCP "does not understand the private sector or have any apparent concern about the burdens and confidentiality issues these proposals place on contractors."
In fact, the OFCCP itself estimated that it would take 103.2 hours and cost $135,000 to collect and provide all the data that could be requested in the revised Scheduling Letter.
The third installment in The Proactive Employer's OFCCP Month line up will focus on this additional data. We'll talk about what additional data you may have to produce, common data collection pitfalls, and the importance of having clean and up-to-date information. We'll also provide some tips on how to clean up your data and some red flags that can signal "dirty" data.