Dave, thanks for your comments and copy of the Civil Service code. As
someone who previously worked at the Cabinet Office I'd agree that this
is a useful code for monitoring ethnicity.
The Cabinet Office itself has a fairly elaborate electronic HR system.
Staff can access it directly to update their personal information,
including disclosing anything in regards to disability, ethnicity,
gender, sexual orientation and caring responsibilities. Equality data
from this system was used to monitor any employment barriers, such as
those to which you refer (grade structure, pay, etc).
In regards to the HE sector, from discussions I have had with HEIs there
are differences in the ways in which they conduct their monitoring. With
the ECU project on staff disclosure I am interested to note the comments
being made in this discussion. With the report ECU hopes to publish next
year on this subject matter any other comments would be gratefully
received.
If you would like to send me any comments please send directly to me at
the email address below.
Regards
Stuart Moore
Policy Adviser
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975
Registered charity, number 1114417
Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn Fields,
London WC2A 3LJ, United Kingdom.
Equality Challenge Unit (ECU) promotes equality and diversity in higher
education. ECU is funded by Universities UK, GuildHE, and the UK higher
education funding bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in
collaboration with Equality Forward in Scotland.
Although every effort is made to ensure that the information contained
within this email is accurate and up to date, ECU cannot be held
responsible for any errors or omissions. The information is not a
substitute for legal advice, and should you require more specific advice
you should consult an appropriately qualified professional advisor.
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system.
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Ratchford, Dave
Sent: 05 August 2008 13:16
To: [log in to unmask]
Subject: Subject: Monitoring via staff records & surveys [was: Re:
Disability - considering someone as disabled]
Dear Katya, Stuart et al,
This is a very interesting discussion. I have to say that I find
Katya's position to be more in line with the many central public sector
organisations I have worked with.
The below is the Civil Service Code of Practice on Recording the
Ethnicity of Staff as agreed with the Cabinet Office and Council of
Civil Service Trade Unions. As far as I'm aware (I've been out of the
loop for the last year), the Code has not been superceded. I've
reproduced the entire thing here as it's only short.
I draw your attention to Paras 4, 5 & 6. Whilst strict confidentiality
is to be maintained there is a clear and definite link to staffing
records, otherwise you cannot practically assess potentially
disadvantaged groups' progress in grade; salary; sickness absense;
grievance and disciplinary stats; promotions; training access etc etc.
We are currently revising our equality monitoring procedures here and I
spoke to the Information Commissioners' Office last week to clarify my
understanding of the Employment Practices Code and Supplementary
Guidance documents. They were clear that the principle of
proprotionality kicks in to underpin the Seventh of the 'Eight
Principles of Data Protection': SECURE. Sensitive data (which
monitoring data is) has to be held securely and that means limiting
access. It doesn't mean nobody having any access - it means being
sensible about who can and who can't have access to this data. You
restrict as much as you can reasonably do so.
Hope this helps.
***************
CIVIL SERVICE CODE OF PRACTICE ON RECORDING THE ETHNICITY OF STAFF
This Code of Practice relates to confidentiality of information gathered
about the ethnicity of staff. Information obtained on ethnicity will be
treated with the highest degree of confidentiality; it will be used only
for the purpose of monitoring the effectiveness of the Civil Service's
policy of equal opportunity and the management and personnel policies of
government Departments and agencies. [Any additional use for ethnicity
data of individuals in individual Departments and agencies must be
agreed with their trade unions and set out explicitly for staff in
Departmental codes.] On no account will data in respect of any
individual be used for any other purpose or made available to any other
body, including government departments, except as set out below.
Methods of collecting ethnicity data
2. Methods for collecting information on the ethnicity of staff may
differ from Department to Department, eg surveys using paper
questionnaires, direct access by individual staff to electronic
personnel records. However, the categories used should conform to those
determined by the Cabinet Office. A model questionnaire and guidance
has been produced by the Cabinet Office, in consultation with the CCSU
and Departments, for Departments and agencies to use in the collection
of ethnicity data. Any variations will need to be objectively justified
and agreed between departments and their trade unions. Confidentiality
of information about individuals should be maintained at all times.
Self-classification or management classification?
3. Data on ethnicity of staff in the Civil Service must be
collected on the basis of voluntary self-classification by individuals.
On no account should personnel/equal opportunities units in Departments
and agencies or individuals' line managers provide or be asked to
provide a classification of the ethnicity of members of staff.
Storing ethnicity data
4. Information on the ethnicity of individuals will generally be
held on Departmental/agency personnel databases linked to individual
personnel records. Strict controls will be in place to protect the
confidentiality and use of the data (as set out in paras 5 & 6 below).
Access to ethnicity data
5. Access to data on the ethnicity of individual staff should be
restricted to individuals in each Department/agency and relevant central
management units for whom access is necessary. It should be made clear
to staff who has access to the data.
Use of ethnicity data
6. Printed records of the ethnicity of individuals set alongside
their name, pay reference number, National Insurance number of other
unique identifier will not be produced, subject to the following
exceptions:
to enable individuals to confirm the accuracy of the record of their
ethnicity;
to inform another Department or agency of the ethnicity of a member of
staff who has transferred to that Department; or
to provide data to an individual/organisation where needed for specific
projects or research to further equal opportunities policies, under
strict confidentiality agreements.
Data can also be transferred electronically where practical for these
purposes. This might be a more practical solution in the event, for
example, of a bulk transfer of staff from one Department/agency to
another.
7. Subject to the exceptions listed above, any output from
departmental staff records which includes information on ethnicity will
always be in the form of counts, tabulations or other statistical
summaries. There is an issue if numbers on statistical summaries are so
small that it would be easy to identify the ethnicity of individuals.
It is Civil Service policy that where there are fewer than 5 people from
any ethnic group identified in summaries, exact numbers will not be
published. Instead, the summaries will indicate that there are '0-4'.
8. The personal data will be used solely for the purposes of
informing and furthering the Civil Service's policy of equal
opportunities. Anonymised statistical data will be also be produced and
made publicly available, including in response to enquiries from
Parliament, employment tribunals and other bodies. The use to which
data on ethnicity will be put will subject to on-going discussions
between Departments/Agencies and their Trade Unions.
9. The data on the ethnicity of individuals collected by
Departments and agencies will also be transferred to the Cabinet Office
to be used for statistical purposes. Such data will be subject to the
National Statistics Code of Practice, and the statistics Head of
Profession in Cabinet Office will ensure appropriate measures are in
place to maintain confidentiality, in line with the National Statistics
Framework.
10. This framework has been agreed by the Cabinet Office and the
Council of Civil Service Unions. It replaces previous codes/guidance on
ethnic monitoring in the Civil Service and will apply in all Departments
and agencies but it may be modified, with the agreement of the relevant
trade unions, to meet Department/agency circumstances.
August 2001
Dave
Dave Ratchford
Equality & Diversity Adviser
Nottingham Trent University
109B Dryden Centre
Dryden Street Nottingham NG1 4FZ
Tel: 0115 848 2904 Fax: 0115 848 6584
[log in to unmask]
http://www2.ntu.ac.uk/EQO
Please note that this communication is in confidence from the Equality
and Diversity Team. If it has reached you in error, please delete
immediately and notify the Team on the above number given by the Sender.
Date: Mon, 4 Aug 2008 09:07:28 +0100
From: Katya Hosking <[log in to unmask]>
Subject: Monitoring via staff records & surveys [was: Re: Disability -
considering someone as disabled]
Dear Stuart (and all),
Thank you, it does help to have the distinction drawn so clearly. But -
and I'm raising this for discussion, not because I think there's any
official right or wrong answer - I wonder if you're over-stating the
usefulness of the first option for statistical purposes?
The coverage of official staff records is comprehensive, even if some
fields remain empty, whereas anonymous surveys (even a census, which is
what you're really talking about) tend to have rather low response
rates, and I'd have thought that makes any conclusions about the
population profile drawn from such a sample unsafe. In my view,
anonymous surveys are much more useful for gathering qualitative
information through free text responses, the content of which can
illuminate the results of monitoring drawn from the HR database.
Besides, I still can't see how an anonymous survey allows you to monitor
processes like promotions or training opportunities - if you send out a
survey which not only asks for equality monitoring information but for a
detailed history of pay, contract type, training attended, and so on, I
reckon the response rate would be close to zero! And in any case, once
you're asking for that level of detail, you're likely to be able to
idenitfy individuals from the responses even if they aren't linked to
staff record numbers.
I suppose I think it's maybe unrealistic to have two parallel
collections of data, covering similar things, where the only real
difference is that one isn't linked to the staff record. It's hard
enough to get people to keep the staff record up to date. Maybe
people's limited goodwill towards surveys could be better used gathering
a different kind of information, one which is also more forgiving when
the response rate is low?
I'd be interested to hear what approach other institutions have taken to
the two methods of gathering information.
all the best,
Katya
>>> Stuart Moore <[log in to unmask]> 01/08/2008 17:10 >>>
Dear Katya
Thank you for your email. I will try and clarify any confusion in
regards to my previous email.
As a starting point I think it is important to recognise that there are
two distinct monitoring systems, which I'll go into further detail
below:
1. Anonymous disclosure through surveys or other mechanisms
2. Consensual disclosure for use on official staff records
1. On the one hand institutions monitor the equality profile of their
workforce for statistical data purposes. Through this process staff
should have the opportunity to anonymously disclose any equality
information, such as whether they are disabled. This process should not
offer any opportunity to identify individuals, for example it should not
be possible to match up monitoring form reference numbers to staff
personal record numbers.
Anonymously disclosed information can be used to enable analysis of
staff from different equality groups within the workforce. This will
enable institutions to monitor pay and employment policies to ensure
there are no barriers or discrimination in these processes or elsewhere
in the workplace, and also to compare to the rates for the other form of
disclosure (described below).
2. The other form of disclosure is when a member of staff discloses to
the employer that they have a disability and gives consent for this to
be captured on their staff personal record. Different institutions will
different mechanisms for recording data on their employees. What is
important is that these records are secure and there is a formal policy
on confidentiality to comply with the Data Protection Act. Monitoring of
this data could be for purposes such as analysing the levels of take up
of support services or reasonable adjustments, which might be useful in
future budgetary planning.
It is more likely than not that institutions will find disparities
between the rates of disclosure from these two different monitoring
processes. These variations could be due to a number of factors,
including staff perceptions of the benefit to them of disclosing this
information, which can be often linked to the culture of the
institution. Research within the equality and diversity sector has shown
that progress towards an inclusive culture can bring greater parallels
between the two disclosure rates.
I hope this response is helpful.
Have a good weekend.
Stuart Moore
Policy Adviser
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975 Registered charity, number
1114417 Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn
Fields, London WC2A 3LJ, United Kingdom.
Equality Challenge Unit (ECU) promotes equality and diversity in higher
education. ECU is funded by Universities UK, GuildHE, and the UK higher
education funding bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in
collaboration with Equality Forward in Scotland.
Although every effort is made to ensure that the information contained
within this email is accurate and up to date, ECU cannot be held
responsible for any errors or omissions. The information is not a
substitute for legal advice, and should you require more specific advice
you should consult an appropriately qualified professional advisor.
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system.
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Katya Hosking
Sent: 01 August 2008 13:23
To: [log in to unmask]
Subject: Re: Disability - considering someone as disabled
Hi Stuart,
As I understand your first point, it sounds as though data for
statistical purposes (that is,
monitoring?) ought to be collected and held separately from the staff
records in an HR database - that's the only way it could be done
anonymously, without the possibility of identifying an individual. Is
that what you had in mind?
If so, wouldn't that severely limit what you could monitor? Unless
disability status is recorded within an individual staff record you
can't link data on disability with any of the other data in staff
records, such as promotions, training, disciplinary action, or whatever.
And I thought that was exactly the point, that we need to be able to see
whether disabled people move through the system differently. Obviously,
that requires consent to the kinds of processing you're proposing to do,
but I'd have thought that's pretty much a minimum for meaningful
monitoring.
Would the requirement of anonymity be satisfied by having different
pages within a staff record, access to some of which is carefully
restricted?
Best wishes,
Katya
Katya Hosking [log in to unmask]
Inclusive Curriculum Officer
Cardiff University
>>> Stuart Moore <[log in to unmask]> 01/08/2008 12:51:07 >>>
Pamela
Seeing as there has been a high level of interest comments from
colleagues in this discussion I thought I would add ECU's perspective.
Firstly, in regards to only whether self-disclosure should count for
statistical purposes. ECU would recommend that institutions operate a
self-disclosure policy for gathering statistical monitoring data on the
workforce profile by equality groups. Disability disclosing for a
statistical purpose should be both a confidential exercise - with
clearly defined controls on who has access to the data - and anonymous,
so that no one can be individually identified from their disclosure,
unless they give their consent otherwise.
Institutions should also be providing opportunities for staff to
disclose for purposes of applying for adjustments or support. Any
personal information should only be used for the purpose for which it
has been disclosed. If disclosed information is being kept on staff
personnel records it is important to maintain and guarantee
confidentiality and ensure that the processes for collecting and storing
such information is compliant with the Data Protection Act. It is
essential that monitoring exercises claiming to be anonymous actually
are and that there are no means that might lead to an individual being
identifiable.
If evidence shows that there is disparity between the levels of staff
who have disclosed anonymously and those that have declared openly it
may be an indication of cultural issues that need addressing within the
institution. For example, a disabled member of staff may feel
comfortable in disclosing to a colleague, but may have reservations
about doing so to the institution (as an employer). Behaviour & culture
change and effective communication channels can play an important role
in encouraging disclosure. Through effective communication the reasons
for monitoring can be explained and confidentiality assured, benefitting
towards trust, confidence and good relations between the member of staff
and the employer.
As Kate Parsons mentioned, ECU is working with a group of institutions
looking at piloting a range of interventions that will encourage greater
disclosure of disability, as well as ethnicity, sexual orientation and
religion and belief. Some of these interventions include:
* Develop staff monitoring forms that encourage disclosure (example of
which, for disability disclosure, is available on pp31-33 of ECU's
Disclosure and Support Issues for Disabled Staff in Higher Education
final report) . A well designed monitoring form should include
explanatory text on the procedure following disclosure; what the HEIs
policy is against discrimination; and what other support is available.
In regards to disability, monitoring forms should use language that
promotes the social model
* Develop robust IT HR self-service systems that are secure in terms of
confidentiality and are able to produce accurate data.
* Review recruitment procedures in order to encourage applications from
disabled people; guaranteeing interviews to disabled applicants meeting
the job requirements. Sign up to schemes such as the 'Mindful Employers
Charter', and the requirements of the 'Two Ticks' scheme. And adopt open
and inclusive recruitment processes, especially for part-time and/or
temporary staff
* Improve data on the whole 'supply chain' from postgraduate study into
academic careers, to identify where inequalities and barriers exist for
people in the different equality categories
* Disseminate good disability equality practice and examine how the
institution meets its duty of care in relation to stress prevention and
the generation of ill-health - looking in particular at a preventative
role for occupational health services
* Use staff intranet sites to provide information on equality disclosure
and what support is available
* Develop staff newsletters to include regular articles on equality and
disclosure issues.
ECU will be keeping the sector informed of the progress of this project
and will be publishing a report in 2009.
I hope you find this response helpful.
Stuart Moore
Policy Adviser
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975 Registered charity, number
1114417 Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn
Fields, London WC2A 3LJ, United Kingdom.
Equality Challenge Unit (ECU) promotes equality and diversity in higher
education. ECU is funded by Universities UK, GuildHE, and the UK higher
education funding bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in
collaboration with Equality Forward in Scotland.
Although every effort is made to ensure that the information contained
within this email is accurate and up to date, ECU cannot be held
responsible for any errors or omissions. The information is not a
substitute for legal advice, and should you require more specific advice
you should consult an appropriately qualified professional advisor.
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system.
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Pamela Graham
Sent: 31 July 2008 09:31
To: [log in to unmask]
Subject: Disability - considering someone as disabled
Dear colleagues
Do you only rely on self disclosure to count staff as having a
disability, record this on the personnel record system and use the data
for monitoring etc.?
Has anyone decided to extend this to include members of staff whom you
know have a disability, either because they have been seen by
Occupational Health or have told you they have cancer or MS etc., but
they do not want to declare them selves disabled? This would rely on the
position that if the University knows someone has a disability we are
liable for all the associated responsibilties and obligations. Do you
think it would be fair to then add this category to their personnel
record and use the data for monitoring etc.
Many thanks
Pamela
Pamela Graham
Equality and Diversity Adviser
Policy & Projects Team
Human Resources
Newcastle University
1 Park Terrace
Newcastle Upon Tyne
NE1 7RU
+44 (0) 191 222 3440
[log in to unmask]
My working days are Wednesdays, Thursdays and Fridays.
If you have any particular requirements in relation to your
communication with or visit to the Equality and Diversity Team please
let us know immediately so we can discuss any equipment or facilities
you may need.
------------------------------
Date: Mon, 4 Aug 2008 09:21:47 +0100
From: Pamela Graham <[log in to unmask]>
Subject: Re: Monitoring via staff records & surveys [was: Re: Disability
- considering someone as disabled]
Dear All
We carried out an anonymous employee opinion survey last year. We got a
48% response rate and 3% of respondents indicated they had a disability.
Our HR records show that we have 2.24% of staff with a disability. We
have concluded that there are more staff with a disability who have not
disclosed. Obviously the employee opinion survey told us a lot more, but
it was useful to know about disability. We are planning some further
actions to promote the definition, relevance of knowing, and support
available.
Pamela=20
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Katya Hosking
Sent: 04 August 2008 09:07
To: [log in to unmask]
Subject: Monitoring via staff records & surveys [was: Re: Disability -
considering someone as disabled]
Dear Stuart (and all),
Thank you, it does help to have the distinction drawn so clearly. But -
and I'm raising this for discussion, not because I think there's any
official right or wrong answer - I wonder if you're over-stating the
usefulness of the first option for statistical purposes? =20
The coverage of official staff records is comprehensive, even if some
fields remain empty, whereas anonymous surveys (even a census, which is
what you're really talking about) tend to have rather low response
rates, and I'd have thought that makes any conclusions about the
population profile drawn from such a sample unsafe. In my view,
anonymous surveys are much more useful for gathering qualitative
information through free text responses, the content of which can
illuminate the results of monitoring drawn from the HR database. =20
Besides, I still can't see how an anonymous survey allows you to monitor
processes like promotions or training opportunities - if you send out a
survey which not only asks for equality monitoring information but for a
detailed history of pay, contract type, training attended, and so on, I
reckon the response rate would be close to zero! And in any case, once
you're asking for that level of detail, you're likely to be able to
idenitfy individuals from the responses even if they aren't linked to
staff record numbers.
I suppose I think it's maybe unrealistic to have two parallel
collections of data, covering similar things, where the only real
difference is that one isn't linked to the staff record. It's hard
enough to get people to keep the staff record up to date. Maybe
people's limited goodwill towards surveys could be better used gathering
a different kind of information, one which is also more forgiving when
the response rate is low?
I'd be interested to hear what approach other institutions have taken to
the two methods of gathering information.
all the best,
Katya
>>> Stuart Moore <[log in to unmask]> 01/08/2008 17:10 >>>
Dear Katya
Thank you for your email. I will try and clarify any confusion in
regards to my previous email.
As a starting point I think it is important to recognise that there are
two distinct monitoring systems, which I'll go into further detail
below:
1. Anonymous disclosure through surveys or other mechanisms
2. Consensual disclosure for use on official staff records
1. On the one hand institutions monitor the equality profile of their
workforce for statistical data purposes. Through this process staff
should have the opportunity to anonymously disclose any equality
information, such as whether they are disabled. This process should not
offer any opportunity to identify individuals, for example it should not
be possible to match up monitoring form reference numbers to staff
personal record numbers.
Anonymously disclosed information can be used to enable analysis of
staff from different equality groups within the workforce. This will
enable institutions to monitor pay and employment policies to ensure
there are no barriers or discrimination in these processes or elsewhere
in the workplace, and also to compare to the rates for the other form of
disclosure (described below).
2. The other form of disclosure is when a member of staff discloses to
the employer that they have a disability and gives consent for this to
be captured on their staff personal record. Different institutions will
different mechanisms for recording data on their employees. What is
important is that these records are secure and there is a formal policy
on confidentiality to comply with the Data Protection Act. Monitoring of
this data could be for purposes such as analysing the levels of take up
of support services or reasonable adjustments, which might be useful in
future budgetary planning.
It is more likely than not that institutions will find disparities
between the rates of disclosure from these two different monitoring
processes. These variations could be due to a number of factors,
including staff perceptions of the benefit to them of disclosing this
information, which can be often linked to the culture of the
institution. Research within the equality and diversity sector has shown
that progress towards an inclusive culture can bring greater parallels
between the two disclosure rates.
I hope this response is helpful.
Have a good weekend.
Stuart Moore
Policy Adviser
=20
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
=20
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
=20
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975 Registered charity, number
1114417 Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn
Fields, London WC2A 3LJ, United Kingdom.=20 =20 Equality Challenge Unit
(ECU) promotes equality and diversity in higher education. ECU is
funded by Universities UK, GuildHE, and the UK higher education funding
bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in collaboration with
Equality Forward in Scotland.=20 =20 Although every effort is made to
ensure that the information contained within this email is accurate and
up to date, ECU cannot be held responsible for any errors or omissions.
The information is not a substitute for legal advice, and should you
require more specific advice you should consult an appropriately
qualified professional advisor.
=20
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
=20
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system. =20 =20
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Katya Hosking
Sent: 01 August 2008 13:23
To: [log in to unmask]
Subject: Re: Disability - considering someone as disabled
Hi Stuart,
As I understand your first point, it sounds as though data for
statistical purposes (that is,
monitoring?) ought to be collected and held separately from the staff
records in an HR database - that's the only way it could be done
anonymously, without the possibility of identifying an individual. Is
that what you had in mind?
If so, wouldn't that severely limit what you could monitor? Unless
disability status is recorded within an individual staff record you
can't link data on disability with any of the other data in staff
records, such as promotions, training, disciplinary action, or whatever.
And I thought that was exactly the point, that we need to be able to see
whether disabled people move through the system differently. Obviously,
that requires consent to the kinds of processing you're proposing to do,
but I'd have thought that's pretty much a minimum for meaningful
monitoring.
Would the requirement of anonymity be satisfied by having different
pages within a staff record, access to some of which is carefully
restricted?
Best wishes,
Katya
Katya Hosking [log in to unmask]
Inclusive Curriculum Officer
Cardiff University
>>> Stuart Moore <[log in to unmask]> 01/08/2008 12:51:07 >>>
Pamela
Seeing as there has been a high level of interest comments from
colleagues in this discussion I thought I would add ECU's
perspective.=20
Firstly, in regards to only whether self-disclosure should count for
statistical purposes. ECU would recommend that institutions operate a
self-disclosure policy for gathering statistical monitoring data on the
workforce profile by equality groups. Disability disclosing for a
statistical purpose should be both a confidential exercise - with
clearly defined controls on who has access to the data - and anonymous,
so that no one can be individually identified from their disclosure,
unless they give their consent otherwise.=20
Institutions should also be providing opportunities for staff to
disclose for purposes of applying for adjustments or support. Any
personal information should only be used for the purpose for which it
has been disclosed. If disclosed information is being kept on staff
personnel records it is important to maintain and guarantee
confidentiality and ensure that the processes for collecting and storing
such information is compliant with the Data Protection Act. It is
essential that monitoring exercises claiming to be anonymous actually
are and that there are no means that might lead to an individual being
identifiable.
If evidence shows that there is disparity between the levels of staff
who have disclosed anonymously and those that have declared openly it
may be an indication of cultural issues that need addressing within the
institution. For example, a disabled member of staff may feel
comfortable in disclosing to a colleague, but may have reservations
about doing so to the institution (as an employer). Behaviour & culture
change and effective communication channels can play an important role
in encouraging disclosure. Through effective communication the reasons
for monitoring can be explained and confidentiality assured, benefitting
towards trust, confidence and good relations between the member of staff
and the employer.
As Kate Parsons mentioned, ECU is working with a group of institutions
looking at piloting a range of interventions that will encourage greater
disclosure of disability, as well as ethnicity, sexual orientation and
religion and belief. Some of these interventions include:
* Develop staff monitoring forms that encourage disclosure (example of
which, for disability disclosure, is available on pp31-33 of ECU's
Disclosure and Support Issues for Disabled Staff in Higher Education
final report) . A well designed monitoring form should include
explanatory text on the procedure following disclosure; what the HEIs
policy is against discrimination; and what other support is available.
In regards to disability, monitoring forms should use language that
promotes the social model
* Develop robust IT HR self-service systems that are secure in terms of
confidentiality and are able to produce accurate data.
* Review recruitment procedures in order to encourage applications from
disabled people; guaranteeing interviews to disabled applicants meeting
the job requirements. Sign up to schemes such as the 'Mindful Employers
Charter', and the requirements of the 'Two Ticks' scheme. And adopt open
and inclusive recruitment processes, especially for part-time and/or
temporary staff
* Improve data on the whole 'supply chain' from postgraduate study into
academic careers, to identify where inequalities and barriers exist for
people in the different equality categories
* Disseminate good disability equality practice and examine how the
institution meets its duty of care in relation to stress prevention and
the generation of ill-health - looking in particular at a preventative
role for occupational health services
* Use staff intranet sites to provide information on equality disclosure
and what support is available
* Develop staff newsletters to include regular articles on equality and
disclosure issues.
ECU will be keeping the sector informed of the progress of this project
and will be publishing a report in 2009.
I hope you find this response helpful.
Stuart Moore
Policy Adviser
=20
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
=20
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
=20
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975 Registered charity, number
1114417 Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn
Fields, London WC2A 3LJ, United Kingdom.=20 =20 Equality Challenge Unit
(ECU) promotes equality and diversity in higher education. ECU is
funded by Universities UK, GuildHE, and the UK higher education funding
bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in collaboration with
Equality Forward in Scotland.=20 =20 Although every effort is made to
ensure that the information contained within this email is accurate and
up to date, ECU cannot be held responsible for any errors or omissions.
The information is not a substitute for legal advice, and should you
require more specific advice you should consult an appropriately
qualified professional advisor.
=20
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
=20
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system. =20 =20 -----Original
Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Pamela Graham
Sent: 31 July 2008 09:31
To: [log in to unmask]
Subject: Disability - considering someone as disabled
Dear colleagues
Do you only rely on self disclosure to count staff as having a
disability, record this on the personnel record system and use the data
for monitoring etc.?=20
Has anyone decided to extend this to include members of staff whom you
know have a disability, either because they have been seen by
Occupational Health or have told you they have cancer or MS etc., but
they do not want to declare them selves disabled? This would rely on the
position that if the University knows someone has a disability we are
liable for all the associated responsibilties and obligations. Do you
think it would be fair to then add this category to their personnel
record and use the data for monitoring etc.
Many thanks
Pamela=20
Pamela Graham
Equality and Diversity Adviser
Policy & Projects Team
Human Resources
Newcastle University
1 Park Terrace
Newcastle Upon Tyne
NE1 7RU
+44 (0) 191 222 3440
[log in to unmask]
My working days are Wednesdays, Thursdays and Fridays.
If you have any particular requirements in relation to your
communication with or visit to the Equality and Diversity Team please
let us know immediately so we can discuss any equipment or facilities
you may need.=20
------------------------------
Date: Mon, 4 Aug 2008 11:05:56 +0100
From: Caroline Old <[log in to unmask]>
Subject: Re: Monitoring via staff records & surveys [was: Re: Disability
- considering someone as disabled]
We have run both a staff survey for statistical purposes and one as a
general survey response.
The Statistical data collection was run for the benefit of the annual
HESA return and as such we got an incredibly high response rate. This
has given us 6% disabled staff return.
Unfortunately surveys related to personal experience etc have often
returned a low response with people not wanting to identify specific
issues or concerns. We certainly have never experienced the same
response rate as the statistical survey that we undertook.
I find the data collated for the HR system is much more useful to
benchmark re,recruitment, learning and development, disciplinary and
grievance etc, and the more general surveys as a tool for staff
consultation which may raise individual concerns.
We are hoping to do some more work at encouraging staff response for our
developing SES as we know that we still have a number of staff who do
not declare. I will share any experiences from the exercise via the
jiscmail.
Caroline
Caroline Old
Equalities Officer
Human Resources
Southampton Solent University
East Park Terrace
Southampton
SO14 0YN
Tel: 02380 319631
E-mail: [log in to unmask]
Please note that my usual office hours are 08:15-17:15 Monday- Thursday.
Katya Hosking <[log in to unmask]> Sent by: HE Administrators equal
opportunities list <[log in to unmask]>
04/08/2008 09:07
Please respond to
HE Administrators equal opportunities list <[log in to unmask]>
To
[log in to unmask]
cc
Subject
Monitoring via staff records & surveys [was: Re: Disability -
considering someone as disabled]
Dear Stuart (and all),
Thank you, it does help to have the distinction drawn so clearly. But -
and I'm raising this for
discussion, not because I think there's any official right or wrong
answer
- I wonder if you're
over-stating the usefulness of the first option for statistical
purposes?
The coverage of official staff records is comprehensive, even if some
fields remain empty, whereas
anonymous surveys (even a census, which is what you're really talking
about) tend to have rather low
response rates, and I'd have thought that makes any conclusions about
the
population profile drawn
from such a sample unsafe. In my view, anonymous surveys are much more
useful for gathering
qualitative information through free text responses, the content of
which
can illuminate the results
of monitoring drawn from the HR database.
Besides, I still can't see how an anonymous survey allows you to monitor
processes like promotions
or training opportunities - if you send out a survey which not only asks
for equality monitoring
information but for a detailed history of pay, contract type, training
attended, and so on, I reckon
the response rate would be close to zero! And in any case, once you're
asking for that level of
detail, you're likely to be able to idenitfy individuals from the
responses even if they aren't
linked to staff record numbers.
I suppose I think it's maybe unrealistic to have two parallel
collections
of data, covering similar
things, where the only real difference is that one isn't linked to the
staff record. It's hard
enough to get people to keep the staff record up to date. Maybe
people's
limited goodwill towards
surveys could be better used gathering a different kind of information,
one which is also more
forgiving when the response rate is low?
I'd be interested to hear what approach other institutions have taken to
the two methods of
gathering information.
all the best,
Katya
>>> Stuart Moore <[log in to unmask]> 01/08/2008 17:10 >>>
Dear Katya
Thank you for your email. I will try and clarify any confusion in
regards to my previous email.
As a starting point I think it is important to recognise that there are
two distinct monitoring systems, which I'll go into further detail
below:
1. Anonymous disclosure through surveys or other mechanisms
2. Consensual disclosure for use on official staff records
1. On the one hand institutions monitor the equality profile of their
workforce for statistical data purposes. Through this process staff
should have the opportunity to anonymously disclose any equality
information, such as whether they are disabled. This process should not
offer any opportunity to identify individuals, for example it should not
be possible to match up monitoring form reference numbers to staff
personal record numbers.
Anonymously disclosed information can be used to enable analysis of
staff from different equality groups within the workforce. This will
enable institutions to monitor pay and employment policies to ensure
there are no barriers or discrimination in these processes or elsewhere
in the workplace, and also to compare to the rates for the other form of
disclosure (described below).
2. The other form of disclosure is when a member of staff discloses to
the employer that they have a disability and gives consent for this to
be captured on their staff personal record. Different institutions will
different mechanisms for recording data on their employees. What is
important is that these records are secure and there is a formal policy
on confidentiality to comply with the Data Protection Act. Monitoring of
this data could be for purposes such as analysing the levels of take up
of support services or reasonable adjustments, which might be useful in
future budgetary planning.
It is more likely than not that institutions will find disparities
between the rates of disclosure from these two different monitoring
processes. These variations could be due to a number of factors,
including staff perceptions of the benefit to them of disclosing this
information, which can be often linked to the culture of the
institution. Research within the equality and diversity sector has shown
that progress towards an inclusive culture can bring greater parallels
between the two disclosure rates.
I hope this response is helpful.
Have a good weekend.
Stuart Moore
Policy Adviser
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975
Registered charity, number 1114417
Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn Fields,
London WC2A 3LJ, United Kingdom.
Equality Challenge Unit (ECU) promotes equality and diversity in higher
education. ECU is funded by Universities UK, GuildHE, and the UK higher
education funding bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in
collaboration with Equality Forward in Scotland.
Although every effort is made to ensure that the information contained
within this email is accurate and up to date, ECU cannot be held
responsible for any errors or omissions. The information is not a
substitute for legal advice, and should you require more specific advice
you should consult an appropriately qualified professional advisor.
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system.
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Katya Hosking
Sent: 01 August 2008 13:23
To: [log in to unmask]
Subject: Re: Disability - considering someone as disabled
Hi Stuart,
As I understand your first point, it sounds as though data for
statistical purposes (that is,
monitoring?) ought to be collected and held separately from the staff
records in an HR database -
that's the only way it could be done anonymously, without the
possibility of identifying an
individual. Is that what you had in mind?
If so, wouldn't that severely limit what you could monitor? Unless
disability status is recorded
within an individual staff record you can't link data on disability with
any of the other data in
staff records, such as promotions, training, disciplinary action, or
whatever. And I thought that
was exactly the point, that we need to be able to see whether disabled
people move through the
system differently. Obviously, that requires consent to the kinds of
processing you're proposing to
do, but I'd have thought that's pretty much a minimum for meaningful
monitoring.
Would the requirement of anonymity be satisfied by having different
pages within a staff record,
access to some of which is carefully restricted?
Best wishes,
Katya
Katya Hosking [log in to unmask]
Inclusive Curriculum Officer
Cardiff University
>>> Stuart Moore <[log in to unmask]> 01/08/2008 12:51:07 >>>
Pamela
Seeing as there has been a high level of interest comments from
colleagues in this discussion I thought I would add ECU's perspective.
Firstly, in regards to only whether self-disclosure should count for
statistical purposes. ECU would recommend that institutions operate a
self-disclosure policy for gathering statistical monitoring data on the
workforce profile by equality groups. Disability disclosing for a
statistical purpose should be both a confidential exercise - with
clearly defined controls on who has access to the data - and anonymous,
so that no one can be individually identified from their disclosure,
unless they give their consent otherwise.
Institutions should also be providing opportunities for staff to
disclose for purposes of applying for adjustments or support. Any
personal information should only be used for the purpose for which it
has been disclosed. If disclosed information is being kept on staff
personnel records it is important to maintain and guarantee
confidentiality and ensure that the processes for collecting and storing
such information is compliant with the Data Protection Act. It is
essential that monitoring exercises claiming to be anonymous actually
are and that there are no means that might lead to an individual being
identifiable.
If evidence shows that there is disparity between the levels of staff
who have disclosed anonymously and those that have declared openly it
may be an indication of cultural issues that need addressing within the
institution. For example, a disabled member of staff may feel
comfortable in disclosing to a colleague, but may have reservations
about doing so to the institution (as an employer). Behaviour & culture
change and effective communication channels can play an important role
in encouraging disclosure. Through effective communication the reasons
for monitoring can be explained and confidentiality assured, benefitting
towards trust, confidence and good relations between the member of staff
and the employer.
As Kate Parsons mentioned, ECU is working with a group of institutions
looking at piloting a range of interventions that will encourage greater
disclosure of disability, as well as ethnicity, sexual orientation and
religion and belief. Some of these interventions include:
* Develop staff monitoring forms that encourage disclosure (example of
which, for disability disclosure, is available on pp31-33 of ECU's
Disclosure and Support Issues for Disabled Staff in Higher Education
final report)
. A well designed monitoring form should include explanatory text on the
procedure following disclosure; what the HEIs policy is against
discrimination; and what other support is available. In regards to
disability, monitoring forms should use language that promotes the
social model
* Develop robust IT HR self-service systems that are secure in terms of
confidentiality and are able to produce accurate data.
* Review recruitment procedures in order to encourage applications from
disabled people; guaranteeing interviews to disabled applicants meeting
the job requirements. Sign up to schemes such as the 'Mindful Employers
Charter', and the requirements of the 'Two Ticks' scheme. And adopt open
and inclusive recruitment processes, especially for part-time and/or
temporary staff
* Improve data on the whole 'supply chain' from postgraduate study into
academic careers, to identify where inequalities and barriers exist for
people in the different equality categories
* Disseminate good disability equality practice and examine how the
institution meets its duty of care in relation to stress prevention and
the generation of ill-health - looking in particular at a preventative
role for occupational health services
* Use staff intranet sites to provide information on equality disclosure
and what support is available
* Develop staff newsletters to include regular articles on equality and
disclosure issues.
ECU will be keeping the sector informed of the progress of this project
and will be publishing a report in 2009.
I hope you find this response helpful.
Stuart Moore
Policy Adviser
Direct tel 020 7438 1023
E-mail [log in to unmask]
Switchboard 020 7438 1010
Fax 020 7438 1011
Equality Challenge Unit
7th Floor, Queens House
55/56 Lincoln's Inn Fields
London WC2A 3LJ
*******************************DISCLAIMER*******************************
****
Equality Challenge Unit
Company limited by guarantee, number 05689975
Registered charity, number 1114417
Registered office: 7th floor, Queens House, 55/56 Lincoln's Inn Fields,
London WC2A 3LJ, United Kingdom.
Equality Challenge Unit (ECU) promotes equality and diversity in higher
education. ECU is funded by Universities UK, GuildHE, and the UK higher
education funding bodies (HEFCE, HEFCW, DEL-NI) and by SFC to work in
collaboration with Equality Forward in Scotland.
Although every effort is made to ensure that the information contained
within this email is accurate and up to date, ECU cannot be held
responsible for any errors or omissions. The information is not a
substitute for legal advice, and should you require more specific advice
you should consult an appropriately qualified professional advisor.
This message is confidential. If you are not the intended recipient you
should not copy or disclose this message to anyone but should kindly
notify the sender and delete the message. Opinions, conclusions and
other information in this message that do not relate to the official
business of ECU shall be understood as neither given nor endorsed by it.
No contracts shall be concluded by means of this e-mail.
Neither ECU nor the sender accepts any responsibility for viruses. The
administrator of this e-mail service reserves the right to access and
disclose all messages sent over its e-mail system.
-----Original Message-----
From: HE Administrators equal opportunities list
[mailto:[log in to unmask]] On Behalf Of Pamela Graham
Sent: 31 July 2008 09:31
To: [log in to unmask]
Subject: Disability - considering someone as disabled
Dear colleagues
Do you only rely on self disclosure to count staff as having a
disability, record this on the personnel record system and use the data
for monitoring etc.?
Has anyone decided to extend this to include members of staff whom you
know have a disability, either because they have been seen by
Occupational Health or have told you they have cancer or MS etc., but
they do not want to declare them selves disabled? This would rely on the
position that if the University knows someone has a disability we are
liable for all the associated responsibilties and obligations. Do you
think it would be fair to then add this category to their personnel
record and use the data for monitoring etc.
Many thanks
Pamela
Pamela Graham
Equality and Diversity Adviser
Policy & Projects Team
Human Resources
Newcastle University
1 Park Terrace
Newcastle Upon Tyne
NE1 7RU
+44 (0) 191 222 3440
[log in to unmask]
My working days are Wednesdays, Thursdays and Fridays.
If you have any particular requirements in relation to your
communication with or visit to the Equality and Diversity Team please
let us know immediately so we can discuss any equipment or facilities
you may need.
------------------------------
Date: Mon, 4 Aug 2008 13:18:47 +0100
From: Heather Griffiths <[log in to unmask]>
Subject: Equality and Diversity Training
Dear all
=20
I want to organise generic equality and diversity training for all
staff at our institution. We are probably looking to outsource the
training and would like to find a training provider which is
professional and engaging with a successful track record of delivering
training within HEI's, whilst at the same time keeping the costs down,
and preferably in or close to the West Midlands. Please would you
give me contact details of any training providers you have used to
good effect for equality and diversity training.
=20
=20
Heather Griffiths
Equality and Diversity Officer
Newman University College
Genners Lane
Birmingham B32 3NT
email: [log in to unmask]
Tel: 0121 476 1181=20
------------------------------
End of ADMIN-EO Digest - 1 Aug 2008 to 4 Aug 2008 (#2008-137)
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