Diversity, data and disclosure: How can D&I teams build a case for data?
By Jo Faragher on 29 October 2019
One of the ways D&I leaders can get the ear of senior stakeholders is with cold, hard data. Used well, the right data can open up a host of opportunities for more evidence-based practice: benchmarking against other organisations, a true view of how diverse your workforce is, the ability to look at issues more intersectionally.
But many organisations struggle to know where to start when it comes to collecting data, compounded by legal restrictions such as GDPR, which requires complete transparency in why data is collected and how it is used. For a huge number of employers, gender pay gap reporting will be their main data focus in diversity, but with ethnicity pay gap reporting potentially in the pipeline and executive pay ratios around the corner, it pays to get more savvy about the value of data and your motivations for collecting it.
At d&i Leaders’ recent Disability at Work Summit, Mark McLane, head of D&I at M&G Prudential, argued that HR was “so far behind” in terms of data collection compared to other areas of the business. He said: “The organisation can’t function without our support so how come we’re not collecting as much data as the rest of the business? People say ‘It’s illegal’ – so show me the legislation.” His point reflects a wave of confusion since the introduction of GDPR, with many parts of the workforce using this as a blanket excuse either not to share personal information or to avoid collecting it to inform future activities.
Furthermore, disclosure is still a huge issue for many employers. A report earlier this year by PwC found that 95% of employers have not analysed their ethnicity pay gap – with one of the key concerns around poor response rates. PwC advised companies to encourage employees to share data by explaining why data is being collected and what it will be used for. Letting people know that it will help the organisation set better targets around inclusivity – and potentially improve pay equity for everyone – shows the value of the exercise as opposed to people feeling ‘scrutinised’. Explaining actions that will be taken on the back of the data analysis will also help sell it into the workforce.
The ‘it’s illegal’ argument is also a misnomer. Under current law, data that employers gather for the purpose of monitoring diversity will often fall within the ‘special categories’ of data under GDPR – such as racial origin, religious or philosophical belief, health conditions or sexual orientation. There is provision within the Data Protection Act (which supplements GDPR) that specifically allows collection of this type of data for the purpose of monitoring equality of opportunity or treatment between different groups. Employees can ask organisations to stop processing data by giving written notice, but otherwise businesses are free to collect this information providing it is for equality purposes. (They must have appropriate policy documents in place, however, that describe how the data will be kept secure and for how long it will be retained.)
The benefits of getting granular with data can be the difference between making real changes or simply launching initiatives because ‘they feel right’. At EDF, for example, data from its inclusion index showed that certain groups within the organisation – including LGBT staff – felt less engaged, which meant diversity investment could be targeted where it was needed. When it came to recruiting more women into male-dominated roles, data unlocked the drop-off points where the company was losing female talent, which helped EDF to focus on plugging those gaps. Sharing success stories – where data has identified issues that have since been acted upon – creates a culture that sees data gathering as important, rather than employees feeling they should keep their personal information to themselves.
It’s important not to forget the data that is readily available and can be used for benchmarking or setting targets. Census data can give us an idea of ethnicity spreads in different areas, for example, while the Office for National Statistics breaks down employment data into most strands that would be of interest to diversity professionals. Independent reports from the likes of The Sutton Trust and the Social Mobility Commission offer a lens on class at work, and there are thousands of individual companies’ gender pay gap reports available to download from the government’s reporting portal. Used in conjunction with data specific to your own organisation (recruitment, attrition, absence are good starting points), data sets such as these can help to build a more rounded view of where your organisation stands in terms of its diversity goals, and help set targets for the future.
The key is to know what you want to do with the data. Government reporting requirements are an obvious incentive, but asking the right questions of data can also help D&I to build more targeted initiatives and talk to senior leaders in solid business terms.
The CIPD has just issued some guidelines in its ‘Diversity Management That Works’ report and makes the following recommendations:
- Collect and analyse high-quality diversity data, separating it into component parts, where possible
- The more – and better-quality – people data employers collect, the better they can design and target D&I activity and evaluate progress.
- Make sure you have employees’ consent when collecting data (especially sensitive personal data).
- Ensure that workforce data is representative.
- Protect collected data in line with legal requirements (explain how it will – and won’t – be used, and ensure that data categories are suitable).
- Aim to analyse reliable data throughout the employee lifecycle.
- Reflect on what data/analysis is needed to progress D&I, and how it can be best collected.
- Review your in-house people analytics capability.
- Make the best use of the data you have and, where data allows, take an intersectional view.
d&i Leaders is a global community of senior diversity, inclusion and HR focused professionals, looking to collaborate, network and accelerate their workplace inclusion strategy.