Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 10/01/2018

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Data Collection and Reporting

Policy: Local agency WIC staff will collect and document racial and ethnic data in Compass in order to meet the responsibilities of compliance and enforcement. The collected Information is maintained on file at both the state and local level for three and a half years.

Regulations: 7 CFR 246.6 (b)(10), 7 CFR 246.8, FNS Instruction 113-1, Title VI of the Civil Rights Act of 1964 and USDA Regulations 7 CFR 15

Procedure/Additional Guidance: The following designations are used for the collection of racial/ethnic categories:

Ethnic categories: - Not Hispanic/Latino - A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture of origin regardless of race. The term “Spanish origin” can be used in addition to “Hispanic or Latino.”

Racial categories: - White: A person having origins in any of the original peoples of Europe, Middle East, or North Africa. - Black: A person having origins in any of the Black racial groups of Africa. Terms such as “Haitian” or “Negro” can be used in addition to “Black or African American. - Asian: A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam. - American Indian or Alaskan Native: A person having origins in any of the original peoples of North and South America (including Central America), and who maintains tribal affiliation or community attachment. - Native Hawaiian or Other Pacific Islander: A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.

Use of Data The participant characteristics from the minimum data set are sent to USDA biennially. This information is compared to state and county racial/ethnic breakdown percentages to determine the effectiveness of WIC to reach potentially eligible populations, identify areas where additional outreach may be needed, and assess cultural diversity and sensitivity of the WIC staff.

Required Steps for Collections of Racial/Ethnic Data Local agency staff must: - Explain to the individual that the data collection is for statistical purposes only and that it is a USDA requirement as part of the certification process. - Inform the individual that it does not affect their eligibility for the program. - Request that the participant self-identify their racial/ethnic background. Participants may choose only one ethnicity but more than one racial category. - Use visual identification to determine the participant’s racial and ethnic categories if a participant chooses not to self-identify a race and/or ethnicity. When performing a visual identification, selection of one or more races is acceptable. - Not second guess, change or challenge a self-declaration made by the applicant as to his or her race or ethnic background unless such declarations are patently false. - Enter the participant’s ethnic and racial data in Compass.