Version: 2026-07-12 draft.
Article I. EducateONE Organizational Policies
Chapter 11. Corporate Records, Minutes, Reports, and Inspection Rights
EducateONE Organizational Policy § 11.9.00. Demographic Information Collection and Confidentiality.
(a) Purpose.
(1) In order to understand the persons and communities EducateONE serves, fulfill legal and regulatory requirements, support institutional planning, and evaluate access and participation, EducateONE may collect demographic information in accordance with this policy.
(2) Demographic information shall be collected and used in a manner that respects individual privacy, avoids unnecessary classification, and preserves EducateONE’s ability to comply with specific legal and regulatory requirements.
(b) Scope.
(1) This policy applies to demographic information collected by EducateONE and its controlled institutions, schools, programs, services, activities, and operations.
(2) Demographic information collected under this policy is self-reported unless a specific legal or regulatory requirement requires another method.
(3) Information collected for demographic purposes does not, by itself, establish eligibility for admission, employment, assistance, accommodations, services, benefits, or any other institutional determination.
(c) Race and Ethnicity.
(1) Unless specific regulatory compliance requires another method, a person answering a question concerning race or ethnicity shall be permitted to write in the race and/or ethnicity with which the person identifies.
(2) EducateONE shall not establish a general list of racial or ethnic groups for demographic self-identification.
(3) When a specific legal or regulatory requirement requires predefined racial or ethnic categories, EducateONE may collect or classify only the additional information reasonably necessary to satisfy that requirement.
(4) EducateONE may use reported race and ethnicity information to determine and document aggregate racial composition.
(d) Gender.
(1) EducateONE shall use the following gender classifications:
(A) Female;
(B) Male;
(C) Non-binary;
(D) Trans Female; and
(E) Trans Male.
(2) Gender information shall be confidential.
(3) To the fullest extent legally permitted, EducateONE shall recognize and identify a person according to the gender reported by that person.
(4) Wherever legally permitted:
(A) Trans Female shall be reported as Female; and
(B) Trans Male shall be reported as Male.
(5) EducateONE shall not investigate, verify, infer, test, challenge, or otherwise attempt to determine a person’s gender beyond the information reported by the person or by the person providing the information on the person’s behalf.
(e) Birthdate and Age.
(1) EducateONE shall collect a person’s birthdate to the best knowledge of the person reporting it.
(2) EducateONE recognizes that a person, including a refugee or displaced person, may not know their exact birthdate.
(3) When an exact birthdate is not known, EducateONE may accept and record the best available estimated or approximate birthdate.
(4) EducateONE may calculate age from the reported birthdate when age information is needed.
(f) Languages Spoken.
(1) EducateONE shall collect the language or languages spoken by a person.
(2) A person may report more than one language.
(3) Language information shall be based on the information provided by the person or by the person providing the information on the person’s behalf.
(g) Disability.
(1) EducateONE shall collect disability information using the definition of disability established under Section 504 of the Rehabilitation Act.
(2) For purposes of demographic collection, a person has a disability if the person:
(A) has a physical or mental impairment that substantially limits one or more major life activities;
(B) has a record of such an impairment; or
(C) is regarded as having such an impairment.
(3) Disability information collected under this policy shall be self-reported and confidential.
(4) Demographic disability reporting shall not require a medical diagnosis or supporting documentation.
(5) Demographic disability information does not, by itself, constitute a diagnosis, eligibility determination, accommodation determination, individualized education program, services plan, or waiver of any right.
(h) Monthly Household Net Income.
(1) EducateONE may collect monthly household net income as optional demographic information.
(2) Monthly household net income means the money actually received by the household after taxes and other deductions.
(3) Monthly household net income shall be reported in terms of United States dollars.
(4) Respondents shall select from ranges established by EducateONE rather than report an exact income amount.
(5) A person shall not be required to answer the monthly household net income question.
(i) Confidentiality and Use.
(1) Individually identifiable demographic information shall be treated as confidential.
(2) Access to individually identifiable demographic information shall be limited to persons with a legitimate legal, regulatory, educational, administrative, research, reporting, or institutional need for the information.
(3) EducateONE may use demographic information for:
(A) legally required records and reports;
(B) aggregate demographic analysis;
(C) institutional planning and improvement;
(D) evaluation of access and participation;
(E) educational and student-support purposes; and
(F) other lawful purposes consistent with this policy.
(4) Demographic information should be reported or published in aggregate form when individual identification is not necessary.
(5) EducateONE shall not knowingly disclose individually identifiable demographic information except as authorized by the person, required by law, reasonably necessary for an authorized institutional purpose, or otherwise permitted under EducateONE policy.
(j) Specific Regulatory Requirements.
(1) When a law, regulation, government form, contract, grant, accreditor, or other binding requirement requires demographic information to be collected, classified, maintained, or reported in a particular manner, EducateONE shall comply with that specific requirement.
(2) A classification required for a specific regulatory purpose shall not automatically replace EducateONE’s general demographic classifications for other purposes.
(3) EducateONE shall limit any additional classification or disclosure to what is reasonably necessary to satisfy the specific requirement.
(k) Interpretation.
(1) This policy shall be interpreted to permit useful and lawful demographic collection while avoiding unnecessary investigation, imposed identity classifications, intrusive verification, and unnecessary disclosure.
(2) Nothing in this policy requires EducateONE to collect demographic information that is not required by this policy, another EducateONE policy, or a specific legal, regulatory, contractual, accreditation, grant, program, or institutional requirement.
(3) EducateONE may establish forms, income ranges, confidentiality controls, reporting methods, and administrative procedures consistent with this policy.
Source Note
This policy was developed for EducateONE based on its institutional decisions concerning demographic collection, self-identification, confidentiality, international applicability, and regulatory reporting.
The race and ethnicity provisions are informed by Revenue Procedure 75-50 and the IRS Instructions for Schedule E, which require private schools to maintain records of the racial composition of their student body, faculty, and administrative staff while permitting estimates based on the best information readily available and not requiring persons to submit information the school does not otherwise collect.
The disability definition is based on Section 504 regulations defining a protected person as one who has an impairment substantially limiting a major life activity, has a record of such an impairment, or is regarded as having such an impairment.
References
Revenue Procedure 75-50, 1975-2 C.B. 587.
IRS Instructions for Schedule E (Form 990), Schools.
Section 504 of the Rehabilitation Act of 1973, 29 U.S.C. § 794.
34 C.F.R. § 104.3.
EducateONE Organizational Guideline § 15.4.01. Policy Layout Standard and Style Guide.
