Ethnicity and disability pay gap reporting – five tips to help organisations improve their data and outcomes

Published: 25 November 2024 | by Silvia Hui, campaign manger at Brightmine, and Robert Shore, HR market insights editor at Brightmine

Although the formal Bill is yet to be published, the Government has outlined plans to require organisations with 250 or more employees to report their ethnicity and disability pay data. To prepare HR leaders for this change, Brightmine and HR Grapevine convened a roundtable discussion to address the practical and cultural challenges of expanded pay gap reporting.

During the event, industry professionals from different functions including DEI, pay analytics and reward came together to share the challenges they currently encounter in collecting employee data. Many said they already collected ethnicity data. A slightly smaller number had collected disability data.

The discussion highlighted key themes, such as establishing trust, addressing privacy concerns and aligning with evolving global reporting requirements. This exchange of experiences and best practices illuminated the steps that organisations need to take to move from compliance to meaningful action.

A watershed moment

As the new legislation takes shape, organisations face a pivotal moment. The task of collecting data is complicated by concerns over privacy, the fear of discrimination and a need for trust. Disclosure rates can be as low as 20%. Building a foundation of transparency is not just about compliance but about nurturing a culture of openness and confidence. Employees need to understand how the data will be used, and organisations need to communicate that purpose clearly.

Five insights to help with data collection and narrowing pay gaps

For HR leaders, it’s essential to build trust and use pay data purposefully. Simply collecting information isn’t enough. When data drives genuine policy changes, employees see meaningful impact and feel encouraged to share transparently. It’s about more than just storytelling; it’s about delivering on promises.

1. Use existing HR processes to collect data

Without accurate insights, organisations cannot identify or close the gaps that persist in the workplace. There was consensus that EDI goals must go beyond numbers on a spreadsheet – they should lead to initiatives that demonstrate real change. Collecting this data is the first step towards fulfilling a commitment to an equitable work environment, where the workforce feels safe to disclose their experiences, knowing that they will be met with action rather than silence and inertia.

Leaders shared that integrating data collection into existing HR processes, like annual performance reviews or engagement surveys, can encourage higher participation. Organisations may use a variety of touchpoints – such as onboarding and employee resource group (ERG) meetings – to create opportunities for employees to share their information confidently.

2. Ask good questions, in the right way

Above all, if you want to collect good data, you need to ask good questions.

The way questions are framed is critical. It was suggested that a closed yes/no question, such as “Are you disabled?”, might not elicit the most useful responses, especially in relation to an area like disability where there are nuances of definition and where the wording “Do you feel disabled?” might be more appropriate to encourage frank disclosure. You could also provide a list and ask: “Do you have one of the following conditions?”

To collect the fullest set of data possible, it is better to make questions mandatory – but always with a “Prefer not to say” option. You may want to avoid offering “Other” as a possible response as some may – for obvious reasons – find the term to be othering.

Think carefully about the number of questions you ask and which channels of communication you use in order to reach employees, who may be in very different working environments: remote and desk-based or on site but deskless, for example.

3. Share the results effectively

The outcome of the reporting process is often invisible to those who take part in it. Make sure reports are readily available and that employees know where to find them and how to access them. It’s also crucial to translate the data into a form that is easy to consume by a wider audience, which will rarely be made up exclusively of data analysts. There are a plethora of options, so be imaginative. Some organisations use video and even animation to bring stories to life.

4. Make sure responsibility for change sits with the right people

The people who gather the data are rarely those who then take decisions based on what it reveals. There is some acknowledgement that pay gap change is inevitably “a long game”, but a sense of frustration at the lack of progress since the introduction of the first reporting requirements means that some feel that it is little more than a box-ticking exercise. Progress on closing gaps will only result from a genuine determination to create action plans that are grounded in the realities of individual businesses.

One thing that stood out in the discussion was that accountability doesn’t rest solely with HR. Effective pay equity efforts require cross-functional collaboration. This means EDI teams, senior leadership and employee groups need to come together with shared responsibility for progress. The power of this approach is that it removes the burden from any single department, ensuring that various perspectives contribute to a truly inclusive strategy.

Consider creating a working group, made up of representatives drawn from different areas of the business – reward, comms, EDI, ERGs – who can bring their knowledge and experience to the review process and then feed into, and even lead, the creation of your action plan.

5. Build support, educate and communicate

It is essential to build allies. These may be drawn from majority groups, who might feel “under attack” from measures associated with pay gap action plans as the status quo may appear to benefit them.

Getting members of the senior leadership to talk about the issues and share their personal experience of them makes a big difference.

Above all, communicate and educate. Think about the most effective ways to reach different members of the workforce, and invest time and imagination in your storytelling.