Diversity monitoring and data protection

Copyright © 2025 LexisNexis
Published by a LexisNexis Risk & Compliance expert
Practice notes

Diversity monitoring and data protection

Copyright © 2025 LexisNexis

Published by a LexisNexis Risk & Compliance expert

Practice notes
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This Practice Note it is intended for commercial organisations in the UK and is not sector-specific. It explains the data protection implications of workforce diversity monitoring, including whether:

  1. •

    you need consent from the individuals concerned

  2. •

    you can fall outside the scope of the data protection regime by collecting data in an anonymised form

Most large commercial organisations collect workforce diversity data and monitor trends. Some organisations will also publish their diversity data on their intranet and possibly their external website. There may also be a sector-specific regulatory obligation to report on your diversity data, eg law firms must report their diversity data to the solicitors regulation authority.

Why is data protection relevant to diversity monitoring?

The UK General Data Protection Regulation (UK GDPR) applies wherever you process personal data. For a definition of personal data, see below: Anonymising diversity data.

The type of data organisations collect when monitoring diversity is very likely to constitute special category personal data under the UK GDPR. There are four main types of special category data:

  1. •

    personal data

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Jurisdiction(s):
United Kingdom
Related legal acts:
Key definition:
Monitoring definition
What does Monitoring mean?

The measurement of radiation levels, concentrations, surface area concentrations or quantities of radioactive material and the use of the results of these measurements to evaluate potential exposures and doses.

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