The need for employers to conduct disability reporting has been brought into sharp focus this week with the publication of an open letter to the Prime Minister calling for mandatory reporting on the number of disabled people in the workforce. The letter also references how changes such as gender pay gap reporting have transformed the conversation in the boardroom, and calls for the government to accept recommendations made by the Centre for Social Justice Disability Commission in a bid to reduce the disability employment gap. According to the TUC, the average disability pay gap is around 20%, and whilst many organisations have proactively started to monitor their disability pay gaps - the BBC for example have started to illustrate their disability pay gap overall and by level - don’t be fooled into thinking this is just another data set to add to the list.
Whilst I agree wholeheartedly that we need to make progress in accelerating and supporting disabled people in the workplace, calling for mandatory reporting isn’t quite as straightforward as is would seem. You are disabled under the Equality Act 2010 if you have ‘a physical or mental impairment that has a ‘substantial’ and ‘long-term’ negative effect on your ability to do normal daily activities’. However, whilst many people, myself amongst them, technically meet the definition, they may not classify or see themselves as disabled. The common misconception is that disability is visible, i.e. there is a physical impairment, but many people have disabilities that are not visible and may not regard their impairment as a disability. Others may worry about discrimination or impact on their career if they disclose they have a disability, or are fearful of not feeling supported by colleagues or managers.
For this reason, if we want to encourage true reporting so that we can monitor the actual situation and address any pay gaps or equal pay risks, there is more work to be done to ensure that employees feel confident to disclose or classify themselves as disabled. This includes taking a people-centred approach, developing awareness, and understanding the barriers to employment for disabled people to find ways to mitigate them. This can start with audits to identify how inclusive your organisation is through employees’ eyes, identifying why disabled people are not disclosing their disability (this could be due to past experience, not feeling confident to disclose etc) and sharing your findings. It is also important to decide on your values around disability inclusion and support your employees & managers to make inclusion a reality. This means if you want employees to disclose and open up, they need to feel they will be heard, and managers and colleagues need to feel they have the right tools to support their colleagues. Many charities have developed toolkits to help with specific conditions to increase awareness and take the stigma out of sharing the practicalities. Specific disability inclusion training and demonstrating commitment to your values through signing up campaigns, such as the Sunflower Hidden Disabilities Scheme, will indicate that you are serious in your intent.
As I have tried to highlight, deciding you want to start monitoring disability pay gaps or conducting an equal pay audit on disability is not as straightforward as collating data for gender pay. That doesn’t mean you shouldn’t start until you have a perfect picture, as you may never actually get the real number of disabled employees in your workforce. The more you monitor and report, the more confidence you will build among employees that you are taking disability and inclusion seriously, and in time, along with other support measures, the numbers will become a true reflection of disability in your organisation.