5010 - Affirmative Action Policy

SECTION I
EQUAL EMPLOYMENT OPPORTUNITY AFFIRMATIVE ACTION POLICY

ARTICLE I
Purpose

To reaffirm and restate the college's continuing commitment to the principles of equal employment opportunity; to increase effectiveness by setting forth the action being taken and to be taken by the college and its employees concerning employment opportunities; and to provide for implementation, self-policing, and a measure for achievement through a comprehensive Affirmative Action Program.

Affirmative Action refers to the collective measures taken to eliminate discrimination and provide equal employment in compliance with applicable laws and regulations.

ARTICLE II
General Policy of Washtenaw Community College

The College shall not discriminate against any person because of religion, race, color, national origin, age, sex, height, weight, marital status, disability, veteran status or any other protected status as provided for and to the extent required by state and federal statutes. Further, the College shall not discriminate against any person because of sexual orientation, gender identity or gender expression.  The College shall work for the elimination of discrimination, (1) in organizations recognized by the college, and (2) by non-college sources where students and employees of the college are involved. 

ARTICLE III

The college will not discriminate against any employee or applicant for employment based on any of the protected statuses contained in Article II of this policy.

Further, the college, through its employment practices and procedures seeks and employs qualified personnel for all of its diverse activities and at all if its facilities and provides equal opportunities during employment by administering each and every phase of its human resource management program without regard to any of the protected statuses contained in Article II of this policy.  In this connection, the college will maintain an Affirmative Action Program to assure its commitment that College employment of women and minorities is aligned with the employed population of Washtenaw County.

ARTICLE IV
Dissemination of Policy

1. Information about the college's nondiscrimination policy and its Affirmative Action Program will be communicated periodically and at least once a year to all employees through college publications and other media.
2. To insure awareness, understanding, and aggressive, meaningful, and effective implementation, the subject of equal employment opportunity and the college's commitment under Federal Executive Order 11246, as amended by Federal Executive Order 11375, will continue to have high priority and will be discussed at appropriate management and supervisory meetings and during employee orientation programs for new employees. It will be a basic item on the agenda for the Board of Trustees of Washtenaw Community College, the Executive Officers and other management and supervisory meetings at least once per year and more frequently as needs indicate. Appropriate staff representatives will be available to assist implementation.
3. Community organizations, news media, secondary schools, colleges, and all recruiting sources will continue to be informed in writing about the college's nondiscrimination policy.
4. Copies of this policy will be sent to each union representing college employees.
5. College publications relating to employment shall include articles covering the college's Equal Opportunity Program, including progress reports and promotions of minorities and women. Pictures will include minorities and women.
6. All college publications relating to employment and advertisements for employment opportunity shall include the phrase, "An Affirmative Action/Equal Opportunity Employer."

ARTICLE V
Implementation Responsibility

EXECUTIVE OFFICES

1. Ultimate responsibility for the implementation of this policy and the college's Affirmative Action Program rests with the President of the College.
2. Each Administrator is responsible for the administration of this policy and the college's Affirmative Action Program within his/her area of responsibility.

ADMINISTRATOR OF THE AFFIRMATIVE ACTION PROGRAM

1. The Administrator of the Affirmative Action Program (Vice President for Human Resources) is a staff assistant to the President, and is responsible to the President for the management of the Affirmative Action Program and coordinating the total effort, including systematizing the review of the program, making periodic audits to measure effectiveness, documenting results, offering and providing advice, and for giving counsel and assistance regarding equal opportunity matters.
2. This will include, in cooperation with administrative or operating units, the following:
   1. An analysis of all classifications to determine whether minorities or women are being under-utilized in the classification. This analysis will be conducted separately for minorities and women, and will consider the availability of those with requisite skills, both within and outside the college.
   2. Periodic preparation of specific employment goals for minorities and women in those areas where analysis has indicated an identifiable deficiency so that areas or divisions or human resources management can take corrective action and measure achievement. It is understood that achievement will be measured by bona fide good faith effort.  Special attention will be given to extending and strengthening efforts to increase the number of women and minority executive officers, deans, directors, supervisors, professional faculty, classified faculty, clerical staff, and skilled workers where these deficiencies exist.
   3. Compilation and maintenance of the supporting data.
   4. Establishment of a procedure which will systematically monitor and provide feedback from area or divisional units. The feedback from the units will include:
      1. Analysis for the hiring of minorities and women,
      2. An evaluation of recruitment and recruitment sources,
      3. A review of promotions and transfers of minorities and women,
      4. A review of the increase or decrease in the size of the work force by minority groups and sex,
      5. Identification of problem areas peculiar to a unit and specific recommendations for overcoming them.
   5. Preparation of a table of Washtenaw Community College staff, grouped by employment classification, including the total number in each classification with a sex and racial breakdown, using current US Census data.
3. In addition, the Administrator of the Affirmative Action Program shall:
   1. Maintain liaison with governmental officials and other groups concerned with Affirmative Action Programs.
   2. Make periodic reports to the college community on the progress of the affirmative action program.
   3. Coordinate data gathering, consolidate data, analyze data, and prepare reports required by external agencies.

VICE PRESIDENT FOR HUMAN RESOURCES

1. The Vice President is responsible for reviewing and developing personnel policies and practices that assure compliance with these equal employment opportunity and affirmative action requirements.

ADMINISTRATORS AND SUPERVISORS

1. Each member of management and supervision is responsible within his/her area of responsibility for conducting activities in a manner which will ensure compliance with this policy and the Affirmative Action Program.

CONSTRUCTION PROJECTS AND SUPPLIERS

1. An individual designated by the President (Director of Campus Development and Auxiliary Services) shall be responsible for monitoring equal development opportunities in all construction projects by suppliers.

ARTICLE VI

Recruitment

1. The college recruits on the basis of qualifications and individual ability without regard to any of the protected statuses contained in Article II of this policy, except where sex, age, or disability is a bona fide occupational qualification.
2. Recruitment sources will continue to be advised, including written notification, of the college's policy and commitment to equal employment opportunity.
3. Recruitment practices will focus on creating a feeling conducive to attracting minority group members and women.
4. The college shall continue to strengthen and develop new recruiting sources from among those specializing and/or oriented toward minority and women applicants, with emphasis on those problem areas where under-utilization has been determined.
5. Recruitment and liaison programs will be continued with secondary schools and colleges having a concentration of minority group members and women and will be included in regular recruitment schedules and visits.
6. The phrase, "An Affirmative Action/Equal Opportunity Employer," will continue to be used on recruiting and other employment publications and advertisements, and the use of minority and women news media will continue to be part of the college's advertising practices.
7. The Office of Human Resource Management shall be responsible for recruiting qualified applicants for all positions, in cooperation with the area having an open position, and shall make special efforts to increase the minority and women applicant pool where under-utilization has been determined.
8. Advertisement of open positions in the Instructional, Administrative/Professional, and Technical categories will be placed in those professional journals and job registries which have proven effective in broadening the applicant pool, including those which are readily available to minorities and women.
9. Where a search committee has been formed to locate candidates for employment, every effort must be made to include minorities and women among its members. The search committee shall utilize methods which are most likely to result in the inclusion of qualified minority and women candidates, particularly in those areas where under-utilization has been determined, in the pool of candidates.

ARTICLE VII

Employment and Placement

1. Applicants for employment shall be considered on the basis of qualifications and individual ability and placed without regard to any of the protected statuses contained in Article II of this policy; the college will continue to display official Equal Opportunity posters in conspicuous places available to employees and applicants for employment.
2. Employment application forms shall be in compliance with applicable federal and state laws.
3. Screening procedures, such as interviewing and testing, shall be validated, standardized, and consistent with applicable laws and acceptable personnel practices. Employment interviewers shall be especially cognizant of the college's policy and equal opportunity commitment so as not to adversely affect the employment opportunities of minorities and women.
4. Records shall be maintained of interviews conducted and the results thereof.

ARTICLE VIII

Training

1. Selection for, and participation in, college training and professional development programs shall be without regard to any of the protected statuses contained in Article II of this policy. Availability of professional development and training programs will be made known through college publications and other media deemed appropriate.
2. Requirements for selection and participation in professional development and training programs shall be established and reviewed periodically to ensure that they are consistent with the objectives of the professional development or training program.

ARTICLE IX

Promotions, Demotions, Layoffs, Recall, and Transfers

1. For the purposes of demotions, layoffs, recall from layoff, and opportunities for promotion, transfer, and filling of temporary openings, and employee's qualifications, including ability to perform the work, physical fitness, and service shall be considered without regard to any of the protected statuses contained in Article II of this policy.
2. To ensure equal opportunity for promotion, the college will continue to make known on a college-wide basis the availability of open positions so that all interested individuals can be considered. Where it has been determined that minorities and women are under-utilized, special efforts consistent with this board policy will be made to correct deficiencies.

ARTICLE X

Facilities and Activities

All college facilities (except showers, locker rooms, and rest rooms) and activities will continue to be maintained on a non-segregated basis.

ARTICLE XI

Personnel Policies

Personnel policies and practices, such as compensation and benefit programs, shall be the subject of periodic review to ensure that they are not inconsistent with applicable and current legal requirements, and that they are administered without regard to any of the protected statuses contained in Article II of this policy.

ARTICLE XII

Community Relations

The college will continue to cooperate and to work with other governmental agencies and community groups, which also have equal employment opportunity objectives, in the development of meaningful approaches and sound techniques in fostering our mutual commitment.

ARTICLE XIII

Subcontractors

1. All subcontractors on government contracts have been and will continue to be notified of college commitments under Executive Order 11246 and of their obligations as a subcontractor.
2. The college will continue to incorporate the Equal Employment Opportunity Clause in each non-exempt first-tier subcontract and purchase order have a face value of $10,000 or more, when applicable, and subcontractors will be required to assure compliance with the provisions of Executive Order 11246 as it pertains to them.
3. When applicable, the college will secure an executed "Certificate of Non-segregated Facilities" for each non-exempt first-tier subcontractor or vendor involved in an award having a dollar value of $10,000 or more. A copy of the executed "Certificate" will be retained in the prime contractor's files for reference purposes and review.

ARTICLE XIV

Monitoring, Reports, and Records

1. The college will implement and maintain a monitoring and reporting system for the purpose of evaluation of this policy and its Affirmative Action Program.
2. Each area within the college shall periodically establish hiring goals for employing women and minorities in all employment classifications to correct any identifiable deficiencies.
3. Every area within the college shall be required to maintain records documenting its "good faith efforts" with respect to the implementation of this policy and the Affirmative Action Program.
4. The Administrator of the Affirmative Action Program, in conjunction with the Office of Human Resource Management, will analyze all data compiled on the nature of staff composition and personnel practices, and shall be responsible for the preparation of reports on all findings:
   1. Staff profiles for each employment classification by race and sex.
   2. Staff profiles for each occupational category by employment classification, within the entire college, showing race and sex distribution.
   3. Analysis of progress towards attainment of goals.
   4. Identification of any deficiencies and problems of discrimination or equal employment opportunity.
   5. Such other reports as may be required from time to time.
5. Grievance procedures at all levels of the college shall be reviewed periodically by the Administrator of the Affirmative Action Program and the Human Resources Management staff to ensure and improve their effectiveness with respect to the processing of discrimination complaints.

ARTICLE XV

Release of Information from Personnel Data Files

1. It is the policy of Washtenaw Community College to carefully control the release of data compiled from personnel files on the nature and composition of college employees, including such factors as race, sex, names, and salaries, to prevent the invasion of privacy
2. While the Administrator of the Affirmative Action Program shall have access to information form personnel records for the preparation of reports and analysis, the release of these data, with the exception of names of employees, in a specified form, shall be restricted to government agencies.3. Washtenaw Community College shall, however, comply with all applicable law or regulation regarding the release of public information.
3. Washtenaw Community College shall, however, comply with all applicable law or regulation regarding the release of public information.

Adopted: January 28, 1975
Under January 24, 1978
Adopted: June 23, 1992
Under Consideration: 2002 (5010)
Revised: February 24, 2015