Last reviewed: 22 June 2022

• Begin with the end in mind – know what you want to achieve with data monitoring and let that determine what you ask.
• You can ask applicants and candidates questions about their health and disability on a monitoring form, as long as the information is kept anonymous and separate from the rest of their application.
• Be open with applicants, candidates and new starters about why you are asking for information about health and disability and what you want to achieve.
• This information is legally sensitive, so ensure you adhere to requirements under equalities and data protection laws.

What is the purpose of data monitoring in recruitment?

Monitoring how many disabled people apply for positions enables an organisation to review its recruitment policies and procedures to avoid unintentionally limiting opportunities for disabled people.

You can use the data you gather to identify barriers in your recruitment practices. It is also useful as a benchmark to gauge success in any subsequent steps you take to improve diversity and inclusion in your recruitment practices.

Begin with the end in mind

Know what you want to find out and achieve by data monitoring before you begin. This will make it clearer what you should ask and how you should ask it.

Share your intentions with applicants, so they can be reassured that this information will not count against them in their applications.

Example – HSBC

Carolanne Minashi, Global Head of Inclusion at HSBC spoke at our 2022 Global Conference about how HSBC uses data monitoring to support the progression of under-represented groups in their workforce.

What can I ask on monitoring forms?

Employers are allowed to ask more on data monitoring forms than in other circumstances, such as at interview. This is dependent on keeping the data that is gathered anonymous and separate from the rest of the applicant’s information.

When it comes to disability, you can ask something like:

• “Do you consider yourself to have a disability?”

You could provide an open answer box where applicants can fill in details of their disability if they want to. However, think about if you need to know any more information – do you just want to know how many disabled people are applying, or do you want to know how many people with specific disabilities are applying? What will  you do with the information people may provide in the ‘further details’ box?

Remember that, even on monitoring forms, candidates may not want to tell an employer about their disability for a variety of reasons. They may fear discrimination, think it is irrelevant, or they may not even consider themselves to be disabled. Do not make answering questions on monitoring forms mandatory – allow candidates to select a ‘prefer not to say’.

Example

An employer wants to know how many applicants identify as disabled. They could ask applicants to complete a monitoring form with a section on disability that looks like this:

“Disability

Do you consider yourself to have a disability?

☐ Yes

☐ No

☐ Prefer not to say.”

Before and after the job offer

What you can and cannot ask candidates changes once you have made them a job offer.

For the purposes of data monitoring this is unlikely to have an impact, as you can ask questions such as “Do you consider yourself to have a disability?” on an anonymous and separate data monitoring form before the job offer.

Data monitoring and new starters

The purposes of data monitoring may change once a candidate becomes a formal employee. Organisations may carry out regular data monitoring exercises to find out how many disabled employees they have and information about adjustments.

As the purpose is different, the questions may be different and require employees to provide more detailed information.

A new starter who joins during or just before a data monitoring exercise may need more information and reassurance about this process, particularly if they have only recently completed a data monitoring form with their application.

For more information about data monitoring and employees, see our resource ‘Data monitoring – Asking about disability’.

Communicating with applicants

When monitoring, ensure you communicate why information is being gathered and what actions have been, and will be, taken in the light of the information. For example, will you be putting in place targets to recruit more disabled employees?

You could provide contact information for an individual within the organisation that applicants can contact with any concerns they have about the data being collected.

As above, don’t make completing a data monitoring form mandatory. Allow candidates to opt not to provide this information if they would prefer not to.

Storing data

Information about health or disability is sensitive personal data and so you will need the explicit consent of the data subject to collect, store and process the information for your specified purposes. This can be something you ask for on the survey itself, but it is important that people fully understand what it is that they are consenting to when they agree. A small tick box or opt out may not be sufficient.

It should also be kept anonymous separate from the rest of the applicant’s information so that it could not be seen to have influenced any decision about employing them.

The law

Under the UK’s General Data Protection Regulations and the Data Protection Act 2018, you must obtain explicit consent to collect, store and process personal information, such as whether someone is disabled. You must be explicit about what you will use the information for when obtaining this consent.

For advice about what you can and cannot do, contact our Advice Service.

Read next

• Data monitoring – Asking about disability
• Can I ask candidates questions about disability?
• Communicating with applicants and candidates

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