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The Equality Act 2010 (Gender Pay Gap Information) Regulations 2017 require public, private and voluntary sector organisations, with 250 or more employees, to report annually on their Gender Pay Gap (GPG) at the end of March. This year we’ve going one step further and we’re also sharing our Ethnicity Pay Gap (EPG) figures.

It’s part of our commitment to achieving our EDI objectives and also supports the delivery of our Equality, Diversity & Inclusion (EDI) Action Plan.

As a workforce, employer and regulator we’re striving to be representative of the communities and society we serve. Pay gap reporting prompts us to examine structural or cultural barriers within our organisation that may be contributing to the pay gap and put in place plans to tackle them. By promoting transparency we can identify and address the factors that are preventing women and individuals from ethnic minority backgrounds from joining the ICO and/or progressing to the most senior roles and contributing to our pay gaps.

Let’s start with our Gender Pay Gap:

The Gender Pay Gap (GPG)

The GPG shows the difference in the average pay between all men and women across a workforce.

It’s different to equal pay which looks at the pay differences between men and women who carry out the same jobs, similar jobs or work of equal value.

The gender pay gap reflects differences in how much men and women are paid across an organisation regardless of their job titles. So, a company might have a gender pay gap if a majority of men are in top jobs, despite paying men and women the same amount for similar roles.

In an ideal world we’d have a 0% pay gap.

At 31 March 2023, on average, our men were paid 7.6% more than women within the organisation.

There are two main reasons for this pay gap:

Our Gender Pay Gap explained

The table shows the overall balance of men and women across the eight bands of our pay range from the highest to the lowest paid.

Grade Women Men
B 77.5% 22.5%
C 67.3% 32.7%
D 67.6% 32.4%
E 59.7% 40.3%
F 61.7% 38.3%
G 49.2% 50.8%
G2 61.9% 38.1%
H 50.0% 50.0%
ICO average 63.0% 37.0%

A plain text description of the gender pay gap table. 

Our workforce is made up of 63% women and 37% men. The gender split at lower grades (B, C, D) shows a higher proportion of women in those grades. This means that, while women make up the majority of our employee population, they’re disproportionately represented at the lower paid grades.

On average, women earn more than men at these grades, but the higher distribution of women in the lower grades when compared with the distribution of men drives the overall pay gap.

In grades E, F, G, G2 and H, on average men earn more than women. This is often because of the length of service for men in those roles.

  • At grades E, F and G2, this is minimal (less than 0.5%)
  • But for G and H, where there are more men (50%) compared with the average for the organisation as a whole (37%), the average pay for men is higher by 3.7% and 15.7% respectively.

It’s these differences which result in the 7.6% gender pay gap.

Ethnicity Pay Gap (EPG)

We’re proud to be proactively publishing our EPG so that we can improve transparency, understand where we need to improve and ultimately create a more diverse workforce.

At 31 March 2023, on average, employees from a white background were paid 7.6% more than employees from an ethnically minoritised background.

That’s because employees from an ethnically minoritised background are represented more highly at lower grades (B and C) than our average for the organisation as a whole of 10%. As with the gender pay gap, this drives the overall pay gap.

We also see the highest pay gap in the highest paid grades (G2 and H), where employees from a white background are paid 8.8% and 12-16% more on average. Like the difference for the gender pay gap, this is largely because of the length of time in the role.

The table shows the split by grade of employees from an ethnically minoritised background and employees from a white background.

Grade Ethnically minoritised background White background
B 22.9% 77.1%
C 15.8% 84.2%
D 6% 94%
E 7% 93%
F 8.7% 91.3%
G 12.7% 87.3%
G2 5.3% 94.7%
H 12.5% 87.5%
ICO average 10% 90%

Plain text of table showing the split by grade of employees from ethnically minoritised background and white background

How do we measure our Ethnicity Pay Gap?

In recent years our EGP is based on a comparison between employees from a white background and employees from all of the ethnic minority backgrounds (Black, Asian and minority ethnic) grouped together.

This year, for the first time, we’ve also broken down our ethnicity pay gap by smaller groups using the ethnic groups defined in the UK government Census. It does create some challenges as we have very few or no employees from some groups. However, if we roll the groups up a level to create larger sample sizes, we have the outcome in the table below at 31 March 2023:

Ethnic Group Average Pay Gap
Black 14%
Mixed/Multiple Ethnic Groups 9%
Asian 5%
White 0%
Other Ethnic Group -44%

Plain text of a breakdown of our ethnicity pay gap by smaller groups

Action we’re taking to reduce our pay gaps

We understand that there is no quick fix to reducing our GPG and EPG. If we’re to make progress in reducing these gaps, we need to take action that looks at every aspect of our organisation, from recruitment to progression, to nurturing an inclusive culture.

We’ve already put a number of actions in place but changes won’t happen overnight and we’ll continue to look at every opportunity to fulfil our commitment to equality, diversity and inclusion at all levels of the organisation:

Our commitments during recruitment

  • We’ll continue to promote flexible and part-time working in all our job vacancies to encourage a healthy work-life balance and an environment that supports colleagues with caring needs which we know, more commonly falls to women.
  • We’ll continue to share interview themes in advance of interviews and remove the requirement for university degree qualifications for the majority of our roles to improve accessibility and any potential barriers to attracting a diverse workforce.
  • We’ll continue to advertise roles in places which specifically target members from LGBT+ community, individuals from ethnic minority backgrounds and disabled individuals to widen the pool of applicants and help us achieve our 2028 diversity targets.
  • We’ll continue to develop targeted recruitment campaigns in sectors and specialist professions where we know there is a lack of diversity. This approach worked well in our Digital Data and Technology department to increase female representation.
  • We’ll ensure our recruitment panels, wherever possible, have a diversity of characteristics and experience.

Career progression

  • We’ll continue to ensure our career banding framework remains fair and consistent for all colleagues.

    This framework enables colleagues to demonstrate how they’ve increased competency and capability in the job role and be rewarded through salary increases across four separate pay bands. A review of the last 10 career banding windows shows a consistency in both career banding outcomes but also the rates in which eligible employees apply across different groups.
  • All our people will have a mandatory EDI related objective as part of their personal development record (PDR). This will help place EDI at the front and centre of people’s minds and ensure it’s a thread that runs through every aspect of the organisation.

Inclusion and wellbeing

We know how important it is to take care of our staff and create a sense of belonging so that we continue to attract and retain the best talent:

  • We continue to develop wellbeing workshops, upskilling staff and setting clear expectations of best practice. This included signposting to additional sources of support.
  • We have made flexible arrangements available to staff where needed to support caring responsibilities.
  • We provide equipment to enable colleagues to work effectively from home, as well as running social activities to bring people together and share information via a dedicated wellbeing intranet site.

Have a question? Then drop our EDI Business partner an email.