1. A number of employers want their Gender Pay Gap Report to be legally-privileged – i.e. providing their data via either an in-house legal department or external lawyers and then using a third-party (like us) to calculate their figures. This is important because although most employers are keen to determine their figures as soon as possible, they may delay publishing them until as late as next spring (but before April 2018 deadline). In the intervening period, unless calculated under legal privilege, an employer would be required (for example, by an employment tribunal) to disclose that they have already calculated their figures.
2. Some employers want to calculate their figures earlier than April and a small minority have already conducted a number of such ‘dummy-runs’. The publication of the draft legislation before Christmas has certainly helped focus employers’ minds and many are already developing a project plan to define and collate their data and then book a time for us to calculate their figures as soon as is practical.
3. Some already have plans in place to calculate their figures themselves, but are using our service to double-check their figures.
4. Where an organisation is part of a wider group, the responsibility for calculating the figures has generally been assumed at group-level; where the figures will be collated and calculated for each employing entity on their behalf.
5. With the calculation of the mandatory figures now arranged, employers are already thinking about what factors may be driving them. Some have already asked us whether we can split their calculations by job family or function, by age band, by service band, etc. This is important as this information can form the basis of the narrative to be included with the mandatory figures. This text can explain how the figures have been calculated (i.e. what is included in the definitions), what is driving them, and what equality and diversity initiatives are being undertaken to address any potential issues.
