Require employers to publish data on gender pay gap, bonus gender pay gap, and proportion of males / females receiving bonuses and in each quartile band.
Employers subject to the GPGR Regulations should be required to publish data relating to their organisations’ gender pay gap (mean and median); bonus gender pay gap (mean and median); proportion of males / females receiving bonus payments; and proportion of males / females in each quartile band
As set out in more detail further below, we also consider that there is a wider set of data which employers subject to the GPGR Regulations can usefully collect, analyse and/or publish in order to develop their evidence base and to assist them with understanding the nature and extent of any gender pay disparities within the workplace.
Consider requiring employers to publish full-time and part-time gender pay gap figures
The Department should consider requiring employers to analyse and publish additional discrete gender pay gap figures for each of full-time, and part-time work; and the proportion of males / females in each quartile thereof, where sufficient numbers make it robust to do so.
Clarify rationale for limiting requirements to publish data on only ethnicity and disability
The Department should clarify the rationale for limiting the requirement in the Act to publish pay information in relation to only ethnicity and disability, and consider including wider characteristics that may impact on gender pay differences, for example, ‘age’ and ‘with or without dependants’.
We note, for example, there is evidence that the gender pay gap for women over 40 is significantly higher than for women under 40 and that the arrival of children accounts for the gradual widening of the gender wage gap with age.
Clarify the specific intent of the requirement to publish pay data on ethnicity and disability
The Department should clarify the intended purpose and focus of the information to be published in relation to the requirement under the Act to publish pay information that includes statistics on ‘workers within each pay band’ in relation to ethnicity and disability.
Specifically, it is not clear what statistics are to be included and if this requirement is intended to mean that the gender data for each pay band should be further cross-tabulated / disaggregated. There is also a need for clarity and guidance for employers on how data in relation to ethnicity and disability should be collected/reported on.
Consider data to be published versus a wider set of data that employers can collect/ analyse
The Department should consider the specific content and format of data and statistics that employers are required to publish, versus a wider set of data that they may be permitted to collect and analyse.
We consider that there is a wider set of data which employers subject to the GPGR Regulations can usefully collect/ analyse in order to develop their evidence base and to assist them with understanding the nature and extent of any gender pay disparities within the workplace. For example, employers in those sectors where overtime is a significant element of remuneration, should be encouraged to voluntarily collect and analyse details of overtime pay, including within different quartiles.
A distinction between which headline figures / data must be published versus data which may be collected solely for the purpose of underlying analysis may aid the understanding of trends without impacting on individual anonymity.
Clarify rationale for the focus on ‘employees’ and/or ‘workers’
The Department should clarify the purpose and rationale for the focus of separate parts of the Act on ‘employees’ and ‘workers’.
We note the requirement for pay information to also include statistics on “workers within each pay band in relation to ethnicity, and disability” . The term ‘workers’ in this context is used in contrast to other provisions in the Act which place a requirement to publish information relating to the pay of ‘employees’ (to see if there is a difference of pay between male and female employees).
Require publication of gender pay data on a common fixed date on employer/ government websites.
Employers subject to the GPGR Regulations should be required to publish gender pay data on a common fixed date on their own website and a designated government website; and consideration should be given to the merits of the date being consistent with the publication dates under the GB GPGR Regulations
While we are recommending that the date of publication should be consistent with the dates used in GB, the Commission has not at this time formed a view as to a frequency for the publication of gender pay statistics in Northern Ireland (e.g. annual or triennial).
Consider coding of employers by Standard Industrial Classification (SIC)
The Department should consider coding employers by Standardised Industrial Coding (SIC). SIC provides a framework for the collection, tabulation, presentation and analysis of data by industry, and provides an established and convenient way of classifying industrial activities into a common structure.