From Monday 3rd June 2019 you will have four weeks to complete your firm’s diversity data and report to the SRA. It is an important exercise – studies show that a diverse workforce has many benefits including being more innovative have better financial returns.
The SRA views lack of diversity as a core risk to the profession. It has been a recurring theme of the SRA Risk Outlook.
And don’t forget Principle 9: ‘You must run your business or carry out your role in the business in a way that encourages equality of opportunity and respect for diversity.’
WHO NEEDS TO COLLECT DATA?
Every firm regulated by the SRA. Your firm’s authorised signatory should have received an email setting out what needs to be done.
The SRA may ‘take further action’ against firms who do not comply.
WHAT DO YOU NEED TO DO?
The best way to think of the process is in 3 stages as follows:
Stage 1 Collect your firms’ diversity data
Stage 2 Consolidate data and report to the SRA
Stage 3 Publish the data
STAGE 1 COLLECT YOUR FIRMS’ DIVERSITY DATA
You need to collect information from everyone including full and part-time employees, those on maternity leave, and temporary employees who are with you for at least 3 months.
The SRA provide a diversity questionnaire that you can use to collect information.
When you send the diversity questionnaire to your employees, the covering email or letter should include the following information:
• Why you are collecting the data – you should point out that it is a requirement of the SRA to do so every two years and that you are interested in monitoring the diversity of your employees and using any opinions to build an inclusive culture
• That there is no requirement to answer every question or even the questionnaire at all and that they can answer ‘prefer not to say’ to any question
• What you will do with the data?
Report to the SRA
Publish a summary that will be done in a way that doesn’t identify individuals (see stage 3 below)
• How long you will store the data and who will have access to it
• Who they need to contact to correct or request information the firm holds in relation to the questions asked
It is also good practice to get the employees written consent to process the information.
Everyone must be given an opportunity to respond and you should encourage your staff to do so. Having said that, you can’t of course force anyone. The SRA accept that you will have some people who will not respond and you will be able to report this information to them. However, we suspect questions will be asked if you have 100 employees and only 2 responses!
STAGE 2 CONSOLIDATE DATA AND REPORT TO THE SRA
You will need to report your diversity data on the mySRA portal. If you have used the SRA’s template questionnaire it should be relatively easy to transpose that data into the reporting tool.
The guidance document is unhelpfully buried on the SRA site – click here to find it.
STAGE 3 PUBLISHING THE DATA
The final step is to publish a summary of your data. You will need to ensure that any data published does not identify any individuals, which is likely to be particularly problematic for smaller firms.
You do not have to include information relating to religion or belief, sexual orientation or transgender status. This information can be sensitive so you will need to make a decision on whether it is appropriate to publish.
The data can be published on your website. Alternatively, you can put a poster up in reception or a publish an article on it. The SRA has provided examples as to ways you can publish the data.
