Section 3: a step by step guide


25 / 1 / 2011 10.47am

It is essential that before you embark on any analysis of your data you need to check it for completeness and accuracy. This means checking the data quality for each of the areas that you are looking at:

  • age
  • disability
  • gender reassignment
  • race
  • religion or belief
  • sex and sexual orientation

Where data is incomplete, you need to decide how you will deal with this for each specific area.  For example, you could decide simply to exclude cases where ethnicity is unknown from an ethnicity analysis, or you could (preferably) include a separate category for analysis of them.

As a matter of course employers may wish to undertake a review of its workforce to address any identified gaps in data or information.
Advice on appropriate tools and processes to undertake this are available from:

 Step 1 - Collecting and analysing pay data

To facilitate the collection and analysis of workforce data, a range of standard reports are available.

These reports enable an organisation wide comparison on pay and grading within all equality strands including, age, disability, gender reassignment, race, religion or belief, sex or sexual orientation.  It is also recommended that you use your ESR system to generate reports where this is appropriate or when the data is more useful.

Step 2 - Causes of pay gaps in all elements of pay

If you have found any significant pay gaps between the average basic pay of protected groups doing equal work, you need to find out which aspects of the pay system are contributing to this. A good source of guidance is the Equality and Human Rights Commission's website:

Find out the reason (s) for the difference in basic pay and make sure that the difference has nothing to do with the age, disability, gender reassignment, race, religion or belief, sex or sexual orientation of the jobholder.

Step 3 - Developing an equal pay action plan

If you found any pay gaps related to protected groups for which there was no satisfactory explanation and justification, you should develop an equal pay action plan. The Equality and Human Rights Commission's website has useful guidance for developing an action plan. As a minimum you should continually seek to improve the quality of your workforce data and find ways of improving the level of reporting by staff in respect to their personal information.

If your audit did not reveal any unjustified pay gaps, then you should continue to review and monitor your pay policies and practices to maintain your current standards. See the Equality and Human Rights Commission website for guidance on ongoing review and monitoring.

You should also note that you are required, under the public sector Equality Duty to publish annual data, which includes gender pay gap information.

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