Doing In-house Diversity Research
Recently, I’ve been trying to ask my colleagues some very personal questions and, perhaps unsurprisingly given that I’ve only been here for a few weeks, it has been harder than I anticipated. Our application for Regular Funding from Creative Scotland, and our equalities policy, both require us to monitor and report on the shape of our workforce in terms of the nine protected characteristics defined by the Equality Act 2010. So, I’ve been trying to come up with the best way to encourage colleagues to provide information about things like their gender identity, religion and sexuality.
Because we’re asking for sensitive personal information, protecting respondents’ confidentiality, and being seen to be doing so, is a key issue; the more confident people are in the confidentiality of the survey, the more likely they will be to fully take part.
What We Learned from our Diversity Research
Originally, we planned to use the same scripting software that we use for all of our surveys (Snap). Then we realised that all of the research team would have access to all of the individual responses. We decided to use SurveyMonkey instead, even though it’s not well regarded by researchers*, because we could restrict access to the individual responses to members of the HR team who already have access to sensitive personal data. We were getting set to finalise it when we checked and found out that SurveyMonkey store the data that’s submitted to them in the USA.
As you may be aware, the Data Protection Act, 1998, requires that personal data should not be transferred out of the European Economic Area (EEA) unless “that country or territory ensures an adequate level of protection for the rights and freedoms of data subjects in relation to the processing of personal data.” While SurveyMonkey is certified as complying with the EU–U.S. Privacy Shield (see also a Culture Republic piece on this), this doesn’t cover the handling of HR data. So, we, and you, shouldn’t be using SurveyMonkey for equality and diversity surveys. This obviously could also apply to any other survey software which stores its data out with the EEA.
In order to resolve this, we spoke to Snap, and they have helped use set up a separate access point where the research team can script and test the survey, and where we can restrict access to the responses to relevant members of the HR team, once the survey is launched. We’re now confident that this
- meets the requirements of the data protection act
- achieves the equality and diversity obligations specified in our policy
- maximises the confidentiality of the participants, encouraging people to take part and
- stands the best chance of giving us the information we need for funding applications.
If you would like to take a look at what we have included in our survey, drop me an email and I’d be happy to share it with you. We obtained some best practice advice previously on which questions to include and how to word them so please feel free to use it as a model for yours.
*I don’t like it because scripting the survey was hampered by the restrictions placed on the free version of SurveyMonkey – you can’t do any routing, you can’t have more than 10 questions, and you can’t have a final page with a closing message.