Ofcom: Committing to equality beyond the pandemic

How Ofcom is conducting equality impact assessments to ensure positive action on diversity and inclusion during the COVID-19 pandemic.

Ofcom is the independent regulator of the UK’s communication services, from broadband, home phone and mobile services to TV and radio. It provides advice and information to thousands of people each year through its website and call centre, and registers complaints from individuals and businesses. Ofcom also ensures that people across the UK are satisfied with what they see and hear on TV and radio, and that programmes reflect the audiences they serve. They have been involved with Business in the Community (BITC) since 2008. 

Assessing impacts for all colleagues

Following on from the ‘maximum flexibility’ and ‘families first’ approach taken by Ofcom at the start of lockdown in March 2020, the organisation undertook a risk assessment, including a full equality impact assessment (EIA) in July. This considered:

  • equality issues that might arise from re-opening their office buildings in August 2020
  • continued home working for most colleagues and the process associated with opting in or out of returning to an office; and
  • whether their enhanced policy offering so far may be disproportionately impacting some groups.

The EIA covered all protected characteristics – including an intersection of women – as well as parents and carers and potential social economic impacts. It was informed by diversity data as well as Pulse staff survey findings.

As part of the assessment, all seven employee diversity networks were consulted alongside formal consultation with elected Colleague Forum representatives and the Union, with findings on mitigating actions published internally. Sex specific considerations included: continued use of Keeping in Touch days; safe breastfeeding facilities; travel burden on pregnant colleagues; and the potential disproportionate impact on progression and performance.

Committing to equality beyond the pandemic

The EIA sat alongside COVID-19 specific initiatives that Ofcom introduced. These included maximum flexibility on working hours and patterns for everyone to manage home schooling, caring and wellbeing, uncapped paid dependant leave for parents and/or carers for when they need some extra help. As well as enhanced voluntary leave provision to support local communities or the NHS, suspension of non-essential projects to reduce pressure and an allowance for employees to purchase workstation equipment to make home working safe and more comfortable. Access to female health screening continued with an anti-body test made available, and employees have access to a range of wellbeing support under Ofcom’s Thrive programme including access to mental health first aiders, virtual GP and use of the Headspace app for all.

The EIA picked up important risk areas when adopting a more hybrid approach to working which Ofcom are reflecting on as part of their strategy. These include performance management and career progression – arguably more acute for women, disabled and minority ethnic colleagues. To mitigate against these Ofcom will be publishing performance management guidance for all managers in relation to the unprecedented events of 20/21. It will run the performance process as normal in 2021, being minded (as per guidance above) that some objectives set at the beginning of the performance year (April 2020) may well have been impacted by a variety of factors associated to the pandemic.

The People team will also run performance roundtables with each group’s senior leadership team to ensure consistency of approach. They will conduct in-depth analysis post performance appraisal to check whether particular groups of colleagues who have been adversely affected by the pandemic (such as those that have had to take dependent leave and/or carers leave or sick leave), have been less favourably rated in comparison to those less affected.

Ofcom continually monitors its risk assessment, including an EIA, in response to new government announcements in each of the nations. In light of the most recent announcements, it will build these based on the proposed phased lifting of restrictions, to understand issues and possible mitigating actions on a forward-look.

Helping you work towards best practice

You can learn more about equality impact assessments in BITC’s Responsible Restructures Toolkit, or talk to your Inclusion Adviser about the support we offer in this area.

 If you are not a member of BITC, and would like to find out more about how we can help you build, and maintain, a diverse and inclusive workforce, get in touch with our team today.


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