By December 1 each year, Maine broadcast stations must place in their public file, and on their website if they have one, a report on their EEO activities and hiring practices for the past year. Here is a checklist of the items that should be in the EEO public file. This report should include all EEO activities for the period December 1 through November 30. Read Davis Wright Tremaine’s EEO Advisory for more information on the EEO public file rules.
The recordkeeping requirements for EEO are very important, because the FCC has been auditing stations’ EEO files at random for compliance. At a minimum:
For every job vacancy, complete an EEO internal Job Vacancy Summary form.
For every job vacancy, retain dated copies of all materials used to fill each vacancy.
Retain all records that prove you notified all requesting organizations of the job vacancy.
Keep all documentation of Outreach Activity to show completion of outreach initiatives.
Retain all records until the FCC grants the station’s license renewal application covering the license term during which the vacancy or outreach activity occurs.