Number:  II.9
Date Issued: Oct. 7, 1991
Date Revised: Sept. 1999


The primary purpose of the Departmental Equal Employment Opportunity Plan is to conduct an objective statistical analysis of the department work force to identify positive employment practices and or problem areas within the organization.

Following the identification of problem areas, creative approaches to correct the problems must be developed. Management involvement in the process is essential, if it is to be a success.

The first requirement of an effective plan is a detailed "self analysis" of the department. Identify your problems, determine the priorities of action and then develop goals and specific programs relative to your needs. Remember the end product will be meaningless, unless it results in "measurable, yearly improvement in hiring, training, and promotion of the best qualified diverse staff within all parts of the department.

In short, the departmental equal employment opportunity plan is a management tool. Equal employment opportunity integrated into the workplace is simply good, sound management and a necessary element of basic merit system principles.


See Personnel Administrative Manual Section II.18. EEO Legal References


See Personnel Administrative Manual Section II.8. Equal Employment Opportunity Liaisons


  1. Each year the Equal Employment Opportunity Commission reports to the Board of Supervisors on the progress made toward meeting the County's approved Equal Employment Opportunity recommendations. The Commission' report is, in part, a compilation of Departmental Equal Employment Opportunity Plans. It is, however, the responsibility of each Department Head to propose, develop, and disseminate departmental goals and objectives reflecting a good faith effort to meet the Department's specific work force needs.

  2. Department Equal Employment Opportunity Plan Format

    The Equal Employment Opportunity Commission, the County Administrative Office, and the Equal Employment Opportunity Office review each departments proposed Departmental Equal Employment Opportunity Plan prior to submitting it to the Board of Supervisors for approval. Each department can assist in this review by including the following elements in their Departmental Equal Employment Opportunity Plan:

    1. Department's EEO Policy Statement - a brief statement, to department employees, by the Department Head reaffirming the Department's EEO Policy.(See Section III. below for policy statement guidelines).

    2. Review of Objectives for Prior Year

      1. Review the action steps and objectives taken from the prior year Departmental EEO Plan.

      2. Describe progress and accomplishment of the prior year's action steps and objectives.

      3. Verify prior year Appointments, Promotions, and Separations by EEO-4 class, classification, ethnicity, and sex.

      4. Describe seminars and internal training programs provided Department employees in the prior year (e.g. -equal employment opportunity - sexual harassment, etc.)

    3. Verify ALL current departmental staff by federally required EEO-4 category, classification, ethnicity, and sex, using reports provided by the Equal Employment Opportunity Office.

    4. Describe current underutilization, if any, using the same format. Use the utilization information from the census report on available labor force to describe underutilization.

    5. Describe Department's EEO plans and activities for the current year

      1. Identify projected vacancies for the current year. Use County and/or Departmental turnover statistics for projections.

      2. Describe Departmental EEO efforts to recruit a broad representation of the groups that reflect the County demographics Be specific.

    6. Equal Employment Opportunity/Nondiscrimination Liaisons - Identify primary Departmental contact person for:

      1. Equal Employment Opportunity issues

      2. Sexual Harassment - Usually two persons of the opposite sex

      3. Disabled employees - also responsible for physical access

    7. Department Management

      1. Identify Department's Executive Management staff by class, ethnicity and sex.

      2. Identify Department's Mid-Management staff by class, ethnicity and sex.

  3. Department Equal Employment Opportunity Policy Statement

    1. Policy Statement

      A written equal employment policy and non-discrimination commitment by top management is an essential first element in the Plan. This policy statement signed and dated by the Department Head is a firm statement of personal/professional commitment, legal obligation, and acknowledgment that equal employment opportunity and non-discrimination are fundamental to the operation of the department.

    2. Contents of the Policy

      The policy statement must unequivocally commit the department to equal employment opportunity and non-discrimination as the basis for all departmental personnel decisions and should include:

      1. A restatement of the department's commitment to equal employment opportunity for all employees and job applicants.

      2. A special equal employment opportunity commitment throughout the department to remedy the effects of any past discrimina tion.

      3. Objectives to set up programs to diversify the department work force where deemed necessary.

      4. The appointment of a top administrator as the equal employment opportunity liaison, with responsibility and authority to implement the Department's Equal Employment Opportunity Plan.

      5. The evaluation of management performance on equal employment opportunity in the same way as performance in accomplishing all other department objectives.

      6. A statement that the success of the department equal employ ment opportunity plan will result in positive benefits to the department through the fuller use and development of previous ly underutilization of human resources.

    3. Dissemination - The Department's Equal Employment Opportunity Plan must provide for formal dissemination. The Plan achieves its real value as a written document when it is publicized both internally and externally so that department employees, other County employees, and the community at large are aware of the department's equal employment opportunity goals. Suggested methods that may be used to disseminate this information include:

      1. Internally within the Department

        1. Managers and supervisors should be informed by written communications directly from the Department Head, including equal employment opportunity goals and objectives in the Department's orientation manuals.

        2. Special meetings held regularly to discuss the Plan and each manager and supervisor's individual responsibilities including their efforts and progress in achieving the Plan's goals and objectives.

        3. Employees should be informed of Departmental Policy through:

          1. The Department Head's Equal Employment Opportunity policy statement in conjunction with federal and state posters placed on bulletin boards and in employee rest areas.

          2. Publicity in Departmental newsletters and publications and statements in employee handbooks and annual reports.

          3. Meetings with all staff including minority, female, and disabled employees to request their suggestions in developing the Plan.

          4. Presentation and discussion of the Departmental Equal Employment Opportunity Plan as part of employee orientation and training programs.

          5. Two-way Communications - The Departmental Equal Employment Opportunity Plan will have little value if all the directives are coming from management with no input from employees. Insure that managers and supervisors develop good listening habits - to determine employee reaction and to anticipate and respond to possible Equal Employment Opportunity problems before they surface or multiply.

          6. Union officials should be invited to cooperate as well. By involving the union at the beginning, management can help prevent or lessen potential conflicts over specific actions in implementing controversial elements of the Departmental Equal Employment Opportunity Plan.

      2. Externally outside of the Department

        1. Outreach Recruitment

          Working with the Personnel Department and the Equal Employment Opportunity Office, recruiting is conducted on a non-discriminatory basis; action is taken to attract qualified diverse groups to jobs within the Department with efforts to outreach previously under-represented groups for all positions including non-traditional jobs.

          Assign staff to develop help-wanted ads that are positive. Portray woman and minorities in non-stereotyped jobs. Include an equal employment opportunity statement in all advertising and back it up by picturing women, minorities, and persons with disabilities to publicize their employment within the department in both general and special - minority and women's - media

        2. Notify all subcontractors, vendors, and suppliers in writing of your Plan and request appropriate supportive action on their part. Include the Board approved Equal Employment Opportunity-Non-discrimination clause on all purchase orders, contracts, leases, etc., with an appropriate revocation clause for non-compliance.

  4. Equal Employment Opportunity Liaison

    Each department shall have at least one equal employment opportunity liaison, who shall have primary responsibility for developing and maintaining the departments equal employment opportunity plan. The Equal Employment Opportunity Liaison shall report administratively and on policy issues directly to the agency/department head. (See Personnel Administrative Manual Section II.8. for specific responsibilities of the Equal Employment Opportunity Liaison.)

  5. Assignment of Responsibilities

    1. Assignment

      The Department Head should assign a high level manager as the EEO Liaison to coordinate the Department's Equal Employment Opportunity Program. For an effective Departmental Equal Employment Opportunity Plan the EEO liaison job must be more than a figurehead position or a token assignment for a minority or a woman. Choose an employee with proven ability to accomplish major program goals and make the position directly responsible to the Department Head. Qualified protected group members will provide effective role models and add credibility to Departmental Equal Employment Opportunity Plan --- but only if they are effective in the job and not chosen merely on the basis of sex or race. The liaison's identity should appear on all internal and external communications related to the Department's Equal Employment Opportunity Program and s/he must be given the necessary administrative support to carry out his or her responsibilities.

    2. Responsibility

      1. The development of the Departmental EEO policy statement, written Departmental Equal Employment Opportunity Plan, internal and external communications. The individual must:

        1. Remain abreast of new laws, guidelines, regulations and programs related to equal employment opportunity by participating in equal employment opportunity seminars and training programs.

        2. Disseminate current legal information and news developments on EEO to responsible department administrators.

      2. Keep top level management and supervisors within the department aware of progress and performance towards meeting the goals and timetables stipulated in the Department's Equal Employment Opportunity Plan. Programs should include specific remedies to eliminate discriminatory practices discovered in the employment system.

      3. Actively participate and coordinate target group recruitment efforts with the Personnel Employment Division and with the Equal Employment Opportunity Officer.

      4. Assist in the investigation and resolution of discrimination complaints filed against their department.

      5. Design, implement, and monitor internal audit and reporting systems to measure the effectiveness of the Departmental Equal Employment Opportunity Plan and Program and determine where progress has been made and where further action is needed. Make specific recommendations and assure that follow-up action is then.

      6. Report, at least quarterly, to the Department Head on the progress or operational problems and deficiencies of each division.

      7. Provide counseling, advice and guidance to individuals and groups within their department in matters related to Equal employment opportunity.

        The Department Head may designate a liaison for Equal Employment Opportunity, Sexual Harassment, Reasonable Accommodation, Contract Compliance and complaint resolution.


      The Board of Supervisors approved this eight step plan for enabling departments to better meet the County EEO Plan and EEO action steps as set by departments, along with any recommendations made by the EEO Commission for each department.

      Step 1.

      The Equal Employment Opportunity (EEO) Commission identifies departments which seem to be having problems based on county data and departmental plans, and a thorough department-by-department evaluation in relationship to the objectives set by Supervisors and the yearly action steps set by the EEO Commission.

      Step 2.

      Departments having more serious problems in meeting EEO action steps are separately analyzed by the Equal Employment Opportunity Officer and EEO Commissioners with each separate issue identified.

      Step 3.

      Review will occur by the EEO Commissioners of department's problems with input from the Personnel Director and staff performing recruitment and examination activities. Analysts and their supervisor are to be invited to the EEO Commission meeting along with the Personnel Director to discuss ed concerning specific departments with the Personnel Services Division supplying any necessary information or statistics.

      Step 4.

      Each Department Head and designated staff will meet with the Commission so that the Commission can discuss those aspects of the department's plans in order to better understand the department's EEO issues and to provide insight and input on how the Equal Employment Opportunity Officer can assist with each department's individual problems, needs, etc.

      Step 5.

      The Equal Employment Opportunity Office and Personnel Department receive direction from the Commissioners on how to assist department with their needs to better achieve their EEO action steps. The EEO Commissioners establish criteria for review of departments.

      Step 6.

      The EEO Commissioners establish a fair and reasonable period of review of each department having special problems or needs. The review period is not to last more than a year from the date on which the Department Head met with the EEO Commissioners to discuss the departmental plan. Departments can ask Commissioners for an extension of the review period based on special circumstances. Extensions are to be granted by a quorum of the Commissioners.

      Step 7.

      If after the review period, departments are not able to show progress in identifying areas of concern, the EEO Commissioners are to meet with the Personnel Director, Personnel Services staff and the concerned department to evaluate the reasons for not being able to meet the EEO action steps, etc. If departments need extra special support, staffing, input, personnel, etc., these will be sought. The EEO Commissioners will seek the CAO's and Board of Supervisors' support to met departmental needs. Any support to achieve EEO objectives should be given evenly to all departments.

      Step 8.

      EEO Commissioners will identify what causes for departments not being able to meet their EEO objectives and seek further remedies to assist departments in achieving their objectives. If Commissioners upon last resort, determine that the problem lies in lack of good faith effort, a letter censuring the department will be submitted with a recommendation for approval by the Board of Supervisors. Any further measures to sanction departments will be by the Board of Supervisors action only.