Gender Pay Gap Reporting - CIPP policy whitepaper


Where possible it was hoped that the work carried out to introduce regulations under section 78 of the Equality Act 2010 for the private and voluntary sector would be mirrored for public bodies, to enable consistency across large organisations in all sectors. Public Sector employers already had existing obligations under the Public Sector Equality Duties (PSED). The aim was not to over burden but where possible provide consistency. Recognising that this is an area affected by devolution, it was proposed in this paper that pubic bodies subject to the Specific Duties Regulations 2011 in England who had 250 or more employees would be required to undertake gender pay gap reporting. The same snapshot date was initially proposed; by then it had changed from the initial 30 April to 5 April, but in response to feedback and in the Government response to the consultation it was announced that, in recognition of existing cut off dates for other equality duties for public sector employers “We intend to change the deadline so that all public bodies are working towards the same cut-off date’ and further ‘agree that 31 March represents a more suitable relevant date for public authorities to capture pay information for gender pay gap calculations.” When consultation began back in 2015, what we knew, and as research had previously shown, was that critical to the delivery would be the provision of clear, concise and accurate guidance delivered in a timely manner and with sufficient detail to enable software developers to ensure that their products could provide an accurate and automated solution to help employers with this latest legislative obligation. WHAT WE KNEWDURING THE ROLL OUT PERIOD

Throughout consultation and the development of regulation it had been widely believed that the power of payroll software has put us in a position to be able to gather the relevant data and be more transparent about our pay processes, without such software the very idea would have been untenable. But this is only part of the picture. Software can indeed provide the data, however the data needs to have been collected during the year (for bonus) that preceded the implementation date of this policy. Not only did no regulations exist for most of that year (2016/17) but also, and more importantly, there was no guidance and no publicity to raise awareness to the thousands of employers who would be required to react and provide the time for the resources to be developed to enable them to meet this new requirement. “Have you tested your Gender Pay Gap data in preparation for the mandatory reporting duty that comes into effect in April 2017?” Of the 825 responses received, 30% stated they had fewer than 250 employees so the duty to report did not apply (a telling number for a government hoping for voluntary reporting). Of the remaining 70%, 24% had already tested their data and 29% were planning to before April but 9% were unaware of the new duty. Given this poll ran until the middle of March, this latter figure was a poor reflection of the publicity that surrounded the delivery of this policy, but the results overall spoke well of the preparations made and importance attached to pay transparency processes by many Payroll and HR professionals. The CIPP Policy team ran a quick poll early in 2017 asking:



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