Summary of ASCL’s response 

What is this consultation about? 
The government is exploring how best to increase transparency and reporting practices that support the cultural changes required to build a more inclusive society. It states that reporting on disability within a workforce has the potential to provide an important baseline from which employers can assess the impact of their inclusive practices on the recruitment and retention of disabled people, but how that baseline is established requires careful consideration.

The consultation is aimed mainly at large employers, representative organisations for large employers, trade unions, disabled people and disabled people’s organisations.

It includes questions on current practice and how workforce reporting on disability might be stepped up, exploring both voluntary and mandatory reporting practices. It covers four main areas:

1. Understanding the current landscape 
2. Benefits and barriers to disability workforce reporting 
3. Considerations if mandatory disability workforce reporting was implemented 
4. Alternative approaches

How did we respond? 
We responded to the consultation on behalf of our members as agents of the employer. The specific nature of the questions for individuals meant that we were unable to respond on behalf of our members as individuals. 

In our response we said that we do not support a move to a mandatory approach on disability workforce reporting and feel that a voluntary approach is most appropriate.

We made suggestions on how the government can raise awareness and increase engagement of large employers (250+ employees) with the voluntary disability reporting framework currently in use, as research has shown that awareness of the framework is low. 
 

Why have we taken this view? 
As public sector employers, schools are bound by the Public Sector Equality Duty and as such already collate, analyse and report various information on their workforce, including protected characteristics. This is collected by the government through the School Workforce Census.

There is a voluntary disability workforce reporting framework in use, but a survey showed that only 21% of respondents were aware of it. The government has no data on how many employers are using it.

It is our view that the government needs to know what it wants from this data, and what data it already collects and holds. We believe that a targeted approach to those large employers not already covered by the Public Sector Equality Duty may be more appropriate and beneficial.  This would ensure that any approach adopted does not adversely impact public sector employers who are already faced with increased workloads as a result of the pandemic and cuts to public funding which inevitably leads to staffing cuts.  Furthermore, we recommend that the government carries out a workload impact assessment to ensure it does not increase the workload of public sector employers and duplicate information that is already collected.

We highlighted that the consultation does not look at inclusion; rather it is focused on identification, monitoring and reporting. We would welcome further considerations of inclusivity in the workplace linked to workforce recruitment and retention strategy.
 
Full response to consultation