Our 2024 pay gap report
Our equality, diversity and inclusion (EDI) objectives set out our intention to ensure that our workplace culture is inclusive and represents the communities and societies we serve.
We are publishing our gender pay gap and, for the second year, we are also sharing our ethnicity pay gap in line with our commitment to our EDI objectives.
Although we have made some improvement in reducing our gender pay gap, our ethnicity pay gap has increased. In line with our EDI objectives, we will be using these results to identify any barriers that may be preventing women and individuals from ethnic minority backgrounds from joining the ICO and progressing their careers with us. We’ll then put plans in place to tackle them.
Last year we also published our disability pay gap figures. We’re not able to do this for 2024 due to low declaration rates. We’ll continue to encourage our colleagues to share disability information and will publish disability pay gap information once declaration rates have increased.
Gender pay gap
The gender pay gap 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, an organisation 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 2024, on average, men were paid 4.8% more than women within the organisation, down from 7.6% in 2023. We’re pleased to see this improvement but recognise that there’s still more work we need to do to further reduce the pay gap.
Our gender pay gap explained:
There are two main reasons for the pay gap:
- Women make up a greater percentage of our workforce at lower grades than higher grades.
- In higher grades (F–H), on average men were paid more than women.
The table below shows the percentage of men and women across the eight bands of our pay range from the lowest (B) to the highest paid (H).
| Grade | Women | Men |
| B | 54.5% | 45.5% |
| C | 69.9% | 30.1% |
| D | 68.2% | 31.8% |
| E | 62.2% | 37.8% |
| F | 60.7% | 39.3% |
| G | 61% | 39% |
| G2 | 58.6% | 41.4% |
| H | 55.6% | 44.4% |
| ICO Average | 64% | 36% |
Our workforce is made up of 64% women and 36% men. In the lower grades (C, D) there are significantly more women than men. Whilst women, on average, earn more than men at these grades, the volume of women, compared to men, drives the overall pay gap.
But this isn’t the only factor that increases our pay gap. In higher grades (F – H), on average men were paid more than women.
- At grades F, G and G2 this is minimal (0.1 – 1.6%).
- At grade H, the average pay is 11.1% higher for a man.
Why has the gap reduced from last year?
The reduction of our gender pay gap from 7.6% in 2023 to 4.8% in 2024 is largely due to changes in the number of women and men in different grades:
- The proportion of women in a more senior role (level G) has increased from 49.2% to 61%. This is in line with our overall gender split.
- The proportion of women at level H has increased from 50% to 55.6%.
- There are now more men working at level B – 45.5% compared to 22.5% in 2023.
All the above figures will help inform how we continue to address the gender pay gap.
Ethnicity pay gap
We’re proactively publishing our ethnicity pay gap for the second year so that we can improve transparency, acknowledge where we need to improve and ultimately create a more diverse workforce that reflects the communities we serve.
At 31 March 2024, employees from a white background were paid, on average, 12% more than employees from an ethnic minority background. This is an increase from 7.6% in 2023.
Employees from an ethnic minority background are represented more highly at lower grades (B and C) than our average for the organisation as a whole, which drives the overall pay gap.
The largest gaps occur at some of the highest paid grades (G and H). This is largely because of length of time in role, with policies such as our career banding framework giving all staff the opportunity to progress within their pay grade over time, based on factors such as their competence, behaviours and impact.
The table below shows the split by grade of employees from an ethnic minority background and employees from a white background.
| Grade | Ethnic minority background | White background |
| B | 15.8% | 84.2% |
| C | 17.5% | 82.5% |
| D | 9% | 91% |
| E | 7.4% | 92.6% |
| F | 11.7% | 88.30% |
| G | 5.7% | 94.30% |
| G2 | 0% | 100% |
| H | 11.1% | 88.9% |
| ICO Average | 10.2% | 89.8% |
We have set a target to increase the representation of colleagues from an ethnic minority background from 10.2% to 18% overall and at our top three grades by 2028. We will continue our work to drive forward EDI initiatives that are focused on attracting and retaining talent so that we can be more representative of our society.
As in 2023, we’ve broken down our ethnicity pay gap using the ethnic groups defined in the UK government census and compared them with colleagues from a white background. There are some challenges doing this, as we have very few colleagues from some of these groups. However, by combining groups together to create larger sample sizes, we have the figures outlined in the table below at 31 March 2024.
This table compares ethnic minoritised groups with those from a white background:
| Ethnic Group | Mean Pay Gap | Median Pay Gap |
|---|---|---|
| Black | 35% | 36% |
| Mixed / Multiple Ethnic Groups | 9% | 3% |
| Asian | 9% | 13% |
| Other Ethnic Group | -7% | -15% |
Why has the ethnicity pay gap increased from last year?
As 10.2% of our workforce have told us that they are from an ethnic minority background, that equates to 104 people. Therefore, relatively small changes to this group can have a large impact on the pay gap.
The increase from 7.6% in 2023 to 12% in 2024 has been largely driven by staff turnover in higher positions. The increase in the pay gap for black ethnic groups from 14% to 35% is also driven by this factor.
When looking at levels G and G2 in particular, the proportion of colleagues from ethnic minority backgrounds has decreased:
- from 12.7% to 5.7% at level G
- from 5.5% to 0% at G2.
It’s clear we have more work to do through our recruitment and retention to increase the diversity of our workforce at these grades.
All the above figures will help inform how we continue to address our ethnicity pay gap.
Action we’re taking to reduce our gender and ethnicity pay gaps
Although we’ve made progress on reducing our gender pay gap this year, we’re disappointed that the ethnicity pay gap has increased. We’re committed to reducing these gaps and ensuring that we have a diverse workforce that represents the communities we serve.
What we have been doing:
In the past year, we’ve been working hard to ensure that we’re fostering an inclusive work environment. Here are some of the things we’ve been doing:
- Training our managers on inclusive leadership so they can better support their teams;
- Refreshing our career banding framework, which impacts how our colleagues increase their salaries. A review of the 2024 assessment window showed that the average number of progression steps for colleagues from an ethnic minority background was 1.3 which is the same as the average number of progression steps for colleagues from a white background;
- Continuing to develop our reasonable adjustments process to make sure it’s embedded and considered at all stages of the employee journey;
- Ensuring our recruitment panels reflect a diversity of characteristics and experience;
- Empowering our internal EDI networks and running webinars and events around key issues and awareness days;
- Giving our staff greater opportunity to share their feedback and ask questions, including the introduction of regular all colleague meetings led by ET, and senior leaders;
- Promoting our wellbeing support which includes access to wellbeing champions and 30 mental health first aiders as well as external support; and
- Alongside our menopause policy, we’ve launched menopause training to help colleagues develop the knowledge, skills and confidence to better support people around menopause.
What we plan to do:
Our commitments to recruitment
- We’ll continue to review and enhance our recruitment processes to ensure it aligns with our EDI objectives.
- We’ll ensure we advertise our roles to diverse communities to widen the pool of applicants.
Career progression
- We’ll continue to ensure our career banding framework remains fair and consistent for all colleagues.
- We’ll identify opportunities for targeted coaching and mentorship for colleagues from an ethnic minority backgrounds to support with their career development.
Inclusion and wellbeing
- We’ll collaborate with our REACH (Race, Ethnicity and Cultural Heritage) network, to identify initiatives that can be added to our EDI objectives and will promote the interests of colleagues from ethnic minority backgrounds.
- We’ll continue to empower our EDI networks.