Diversity monitoring

STOP PRESS: This document is being updated to reflect implementation of the Data (Use and Access) Act 2025 (DUAA 2025) which amends the UK GDPR and Data Protection Act 2018. For more guidance on the compliance implications of DUAA 2025, see Practice Note: Data (Use and Access) Act 2025—compliance implications.

This subtopic 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.

The type of

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