The time has come again for all SRA-regulated firms to ask their staff to provide their diversity characteristics such as ethnicity, age, gender identity and educational background. The window for submitting the data to the SRA opened on 4 June 2019 and closes four weeks later, on 2 July 2019.
Given the time-consuming nature of the process, and the many pitfalls which firms may encounter, it is important that all SRA-regulated firms act now.
Submitting the data to the SRA
The diversity information, once compiled, should be submitted to the SRA via the portal on its website.
Submitting the data to the SRA is a regulatory requirement and the SRA may take enforcement action if firms fail to do so by the 2 July deadline.
Collecting the data
The format of the SRA’s template questionnaire is similar to that used in the last reporting round in 2017, but there are some issues of which firms should be aware, such as:
The collection and compilation of the data can be outsourced, but firms should note that this also raises its own GDPR and regulatory issues.
Publishing the data
The SRA expects most firms to publish their diversity data on an anonymised basis, but many firms (or their UK offices of larger firms) will be too small to ensure that the data is truly anonymous. There is no need to make a formal application to the SRA to waive the publishing requirement if a decision is taken not to publish data for this reason, but it is important that the rationale for that decision is adequately recorded.
Further information about the process can be found on the SRA’s website at: www.sra.org.uk/diversitydata. At Fox Williams we advise firms on the process, notably in relation to data protection issues, which can be particularly challenging.
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