How to use your data

The first step is monitoring ethnicity at every stage of the recruitment cycle so that your organisation can gain a greater awareness and understanding of the ethnic composition of your workforce.

To achieve this, it would be beneficial for your organisation to examine any existing data available that indicates:

• Details of your recruitment processes and policies.
• Who applies to work at your organisation.
• Who the successful candidates and what happens to them after they are hired?
• How to retain your staff.
• Who participates in training and development?

It is equally important to consider in advance whether your organisation's data storage and retrieval systems are capable of producing data and analysis for your organisation's current and future requirements.

Organisations should carefully plan their internal communications around the data collection process by consulting with all levels of management, and other key employee resources/ network groups about:

• What you are proposing to do with the data and why.
• How you will use the resulting information so that they can proactively support the drive to improve declaration.
• Making sure the groups you consult are diverse.

It is advised that any information that your organisation intends to capture relating to ethnic origin is separated from the main body of an application form, including a system to ensure that a link can be made for monitoring purposes.

On-line applications using the internet are becoming increasingly popular, and it is important to think about how monitoring information can be gathered so that it does not deter applicants whose data is being captured.

How you can ask questions about ethnic origin

• In the body of an application form – in a separate section to make it clear that the question is not being used for selection purposes. 
• On a separate sheet, titled 'Monitoring Form' linked to the application form.

What to consider when using CV’s to gather information

• Where CV’s are used as a way for your candidates to apply for a role, it may be worth writing to applicants asking them to complete a monitoring form.
• Some organisations invite applicants to telephone in advance before submitting CVs, and include monitoring questions at that point. 

What to consider when recruiting through external agencies 

• If you are using an external agency to conduct a recruitment, ensure a discussion takes place to identify how best to capture the monitoring information required, and in what form, as early on the in the process as possible.
• Recruitment agencies should adopt a process to monitor the diversity of all job applicants in their system which would enable any subsequent review and follow up action to be analysed by organisation and by diverse group.  

What to consider when monitoring initial enquiries 

• If your organisation begins monitoring at the application stage (that includes people who enquire about vacancies but do not follow them up) then the staff members who are the first point of contact should be trained in how to capture information about ethnic origin in a sensitive and legal way.
• Ensure that your monitoring proposals are aligned to your D & I Inclusion policy
• Run a pilot of the proposed monitoring exercise in one department of your organisation, and/or for one or two recruitment exercises.

How to manage the information that you collect

• The key requirement is to make all efforts in collecting and storing information in ways that can maintain a permanent link with the individual to whom it relates.
• This is can easily be achieved using a computer database, which also provides the flexibility to analyse the data in a number of ways.
• The Data Protection Act 1998, which is the UK's implementation of the General Data Protection Regulation (GDPR), provides for confidentiality and for access to their own data by the individuals to whom it relates.  

Understand and adhere to confidentiality 

• Any information related to an individual collected through monitoring is confidential, and must be protected from misuse.
• It is important to also assure all employees of the security of the data, and to have transparent and clear policies about who exactly within the organisation has access to it.
• All employees and job applicants must be informed of the precise reasons for collecting the monitoring information.  

Who should have access to the information? 

• Data that employers gather for the purpose of monitoring equal opportunities will often fall within the special categories of data under the GDPR, i.e. where it relates to employees' racial or ethnic origin, religious or philosophical beliefs, health or sexual orientation.
• The Data Protection Act 2018, includes a limited provision that specifically allows these types of special category data to be processed for the purpose of monitoring equality of opportunity or treatment between different groups.
• An employee can require the employer to stop processing their data for that purpose by giving the employer written notice. The employer can rely on this provision only if it has an appropriate policy document in place, setting out the safeguards it has implemented for processing special category data and its policies on for how long the data will be retained.

• Think about your organisation’s reason for needing the information, and how you are going to use it before designing questions or collecting any data.
• Consider how the data will be analysed, e.g. can the software used generate the type of statistics and reports required?
• You need to collect and analyse data for each stage of the recruitment cycle to understand the full picture, including success or failure statistics at each stage of your recruitment or retention processes.
• Do not use information collected through monitoring for any other purpose than that specified at the beginning, without first communicating why the information is being put to this new use.

Missing monitoring information should be treated as any other missing management information. We advise the following to ensure a good amount of responses for monitoring and review:

• An initial reminder should be sent to individuals who did not specify their ethnic origin, and an appropriate follow-up letter can be used if the data is still not received.
• You may also want to consider involving their line manager in asking for the information in a sensitive way, explaining the purpose of the exercise.
• This is a sensitive area as people may feel threatened by the questions, and become more anxious if follow-up takes place without proper communication of the purpose of the exercise beforehand.