Comment from Anonymous

To the U.S. Equal Employment Opportunity Commission: I oppose the proposed rule rescinding the EEO-1 through EEO-6 reports and eliminating the recordkeeping tied to them. For nearly sixty years, these reports have been the federal government's only systematic record of how employers hire and promote by race, ethnicity, and sex. Without it, patterns of discrimination become far harder to identify — not because they stop, but because the data to see them will no longer exist. If employers aren't required to count, no one can reliably show a pattern. I write as a woman of color who has spent nearly twenty years producing film and television. My industry shows exactly what this rule would spread everywhere: there is no federal employer-by-employer dataset for entertainment, so the only numbers that exist come from outside academics counting film credits by hand, not from the agency charged with enforcement. USC Annenberg and San Diego State studies found women held only about 23% of director, writer, producer, EP, editor, and cinematographer credits on the top 250 films in 2025, flat since 2020, and just 7% of cinematographer credits. In 2023, six Black women executives, several leading DEI efforts at major studios, departed senior roles within a single month, a pattern observers called alarming precisely because no hiring or retention data was ever required to be disclosed. Issa Rae has since spoken about DEI becoming "a bad word" in Hollywood, with executives of color tiptoeing to keep their jobs. EEO-1 data, filed at the employer level, is meant to surface exactly this kind of pattern with more rigor than a headcount ever can. Rescinding it removes the one tool that could hold a specific company accountable, not just the industry as a vague, unaccountable whole. Three points for the record: 1. This removes an evidentiary foundation, not just paperwork. The EEO Data Reports are how the Commission has identified which industries or job categories warrant scrutiny, and how researchers and civil rights organizations have tracked long-term trends. Eliminating the recordkeeping requirement — not just the filing — removes the underlying data before any real need for it can even be assessed. 2. The stated legal rationale deserves scrutiny. The NPRM claims the reports are "inconsistent with equal employment opportunity law" and may be unconstitutional because collected without individualized suspicion. Courts have long distinguished aggregate, anonymized workforce reporting from individualized data used against a specific person. The Commission should explain why that distinction no longer holds, rather than assert it. 3. Rescission removes a self-assessment tool, not just a federal one. Many employers use their own EEO-1 data to benchmark against their industry and correct disparities before they become liabilities. Eliminating both the filing and the recordkeeping obligation takes that away even from employers who want to use it responsibly. I urge the Commission to withdraw this proposal, or at minimum preserve the underlying recordkeeping requirement even if annual filing is streamlined. Keeping records is not the same burden as filing reports, and it is the recordkeeping that preserves the ability to answer whether hiring and promotion patterns have been fair. Thank you for the opportunity to comment. Respectfully submitted, A member of the public Woman of color working in film and television production