Hi Jess,
That’s a tough call because those specific examples really could go a few different ways. It looks to me like the categories are roughly separated by continent, but that Asia-Europe boundary seems pretty squishy, and Caribbean is possibly a blend of 3, 5, or more groups. A few specific island are called out, though that’s pretty general.
There’s no “Different Identity” or “Prefer not to” option in the minimum list, but do you know if your client’s reporting documents offer those anyway (my County-level reporting has several ways to say “No”)? It might be that that in the case where someone doesn’t choose one of the minimum (7), they are assigned one of the no-response categories because we just can’t assume. I would guess you’d have to work with the client to create a policy and stick to it. As you probably saw ,the Register simply says: "When coding write-in data, imputing missing data, or otherwise editing responses, agencies must adopt practices that maximize comparability between data collected on forms and surveys with and without write-in fields. …".
I think I mentioned in a different post that I’m working on transitioning my org from a single write-in box to this new format for exactly the conundrum you present–I am extremely uncomfortable choosing a box for someone else. Clients should be presented with the options and choose for themselves.
I don’t think I’ve answered your question at all but maybe it’s food for thought for others with far more experience than me to jump in. I just happened to searching for this info a lot lately. ETA: reiterating that this is relevant for USA. Would be curious how other countries address this though.
Sounds like you’re familiar with the document but as reference for other forum readers, I’ll paste in the full text from the document. It focuses a lot on “origins.”
[Emphasis is my own]
1. Categories and Definitions
The minimum categories for data on race and ethnicity for Federal statistics, program administrative reporting, and civil rights compliance reporting are defined as follows:
American Indian or Alaska Native. Individuals with origins in any of the original peoples of North, Central, and South America, including, for example, Navajo Nation, Blackfeet Tribe of the Blackfeet Indian Reservation of Montana, Native Village of Barrow Inupiat Traditional Government, Nome Eskimo Community, Aztec, and Maya.
Asian. Individuals with origins in any of the original peoples of Central or East Asia, Southeast Asia, or South Asia, including, for example, Chinese, Asian Indian, Filipino, Vietnamese, Korean, and Japanese.
Black or African American. Individuals with origins in any of the Black racial groups of Africa, including, for example, African American, Jamaican, Haitian, Nigerian, Ethiopian, and Somali.
Hispanic or Latino. Includes individuals of Mexican, Puerto Rican, Salvadoran, Cuban, Dominican, Guatemalan, and other Central or South American or Spanish culture or origin.
Middle Eastern or North African. Individuals with origins in any of the original peoples of the Middle East or North Africa, including, for example, Lebanese, Iranian, Egyptian, Syrian, Iraqi, and Israeli.
Native Hawaiian or Pacific Islander. Individuals with origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands, including, for example, Native Hawaiian, Samoan, Chamorro, Tongan, Fijian, and Marshallese.
White. Individuals with origins in any of the original peoples of Europe, including, for example, English, German, Irish, Italian, Polish, and Scottish.