Low disclosure, high stakes: What your pay gap data is trying to tell you

A key blind spot I keep seeing in organisations is that they struggle to look beyond their poor ethnicity and disability pay gap figures.

Yes, the figures matter. Pay gap reporting is built around them, so it's natural that the numbers command the attention. But I'm increasingly seeing too much focus on this one element, at the expense of everything else.

What do I mean by this?

In private conversations, many share about how bad their ethnicity or disability pay gap figure is and how bad it will look once they have to publish it. There's real anxiety about reputation, about how stakeholders will react, and about what the headline number will say about them.

But very few are asking the more important question: why does it look the way it does?

That is the real question. A pay gap figure is not the problem in itself. It's the symptom, the output of a series of decisions, structures and experiences within your organisation. Treating the number as the whole story is a bit like focusing on a fever without asking what's causing it.

A pay gap is rarely the result of one thing. It typically reflects a combination of factors, which might include:

• Representation at different levels.
• Who is concentrated in lower-paid roles, and who is present in senior, higher-paid positions?
• Recruitment and progression. Who is being hired, who is being promoted, and how quickly?
• Access to opportunity. Who gets stretch assignments, sponsorship, development and visibility?
• Culture and trust. Do people feel safe and supported enough to bring their whole selves to work, including sharing information about their identity?

Until you understand these underlying drivers, any action plan risks being cosmetic. You can't fix what you haven't diagnosed.

Then, there's another layer that often gets overlooked: the quality of the data itself.

Not everyone will want to share their ethnicity or disability status, and that's completely fine. People have the right to as much data privacy as they choose, and that right should always be respected. Disclosure must be voluntary and organisations can't pressure anyone into sharing personal information.

But this is where the tension grows. When an organisation has extremely low return rates on its diversity data, yet describes itself as inclusive, something is wrong.

Low disclosure rates are rarely random. They often signal that people don't trust how their data will be used, don't believe anything will change as a result, or don't feel safe enough to share. Employees who have seen previous surveys lead to nothing, or who worry about being treated differently, will understandably opt out.

In other words, a low return rate isn't just a data problem. It's a cultural indicator. It tells you something about the relationship between your people and your organisation, and that relationship is exactly what inclusion is meant to be about.

If you're worried about what your ethnicity or disability pay gap figures will show, the answer isn't to obsess over the number or to hope it goes unnoticed. It's to get curious about what's driving it.

Some practical places to start:

• Look at your disclosure rates. If they're low, ask honestly why, and listen to what your people tell you.
• Be transparent about purpose. Explain clearly why you're collecting data, how it will be used and who can see it.
• Close the loop. Show people what has changed as a result of the information they've shared. Trust is built through visible action.
• Analyse beyond the headline. Examine pay, progression and representation across levels and functions to find where the gaps actually emerge.
• Commit to a plan. Publish your figures (internally to start) alongside a credible, evidence-based account of what you're doing about them.

The numbers matter, and they will be scrutinised. But organisations that only concentrate on how the figures look are missing the opportunity to understand what they mean.

The organisations that will make genuine progress are those willing to ask harder questions: why does our data look like this, and what are our people telling us through the information they do, and don't share?

That is where your focus should be.

Ready to look beyond the numbers?
If you’re preparing for ethnicity or disability pay gap reporting and want to understand what’s really driving your figures, I can help.

I work with organisations to:

• Diagnose the root causes behind their pay gaps
• Understand and improve disclosure rates in a way that builds trust
• Develop credible, evidence-based action plans they can publish with confidence

Get in touch to start a conversation about what your data is really telling you.