Collecting equality data is one of those HR tasks that's easy to treat as box-ticking. Send the form, store the responses, and repeat next year. The problem is that when it's treated that way, it doesn't do anything. Organizations that get value from equality monitoring are the ones that actually look at what the data is telling them.
This article covers what the form should include, what to do with the responses, and provides a template ready to adapt.
What the equality and diversity monitoring form is collecting (and why)
An equality and diversity monitoring form asks individuals to voluntarily share information about their protected characteristics under the Equality Act 2010. These are: age, sex, disability, race and ethnicity, religion or belief, sexual orientation, gender reassignment, marriage or civil partnership, and pregnancy or maternity.
In the US, the EEO-1 report uses specific race and ethnicity categories defined by the EEOC, including Hispanic or Latino, White, Black or African American, Native Hawaiian or Other Pacific Islander, Asian, American Indian or Alaska Native, and Two or More Races. If you're subject to EEO-1 requirements, your form should align with these categories.
The form is typically issued in two situations: to job applicants as part of a recruitment process, and to existing employees on a periodic basis for workforce reporting purposes. Participation is always voluntary. The responses should never influence any selection, promotion, or assessment decision, and whoever is running those processes should not see individual responses.
What the data is actually for is pattern recognition at a population level. Are certain groups underrepresented at senior levels? Is there a pay gap across demographic lines? Are development opportunities distributed equitably? Those questions require data to answer. The form is how you get it.
What to include in an equality and diversity monitoring form
Every question on the form should offer a "prefer not to say" option. Alongside that, the form's introduction needs to state clearly that participation is voluntary, that responses are confidential, and that they will not be seen by anyone involved in any selection or appraisal process. People are more likely to complete it if they trust what's going to happen with their answers.
Standard questions cover:
- Age: As a range, e.g. under 25, 25-34, 35-44, 45-54, 55-64, 65 or over, prefer not to say
- Sex: Male, female, non-binary, prefer not to say
- Gender identity: Whether the person's gender identity matches the sex registered at birth: yes, no, prefer not to say
- Ethnic group: Using the ONS categories, which include options across Asian, Black, Mixed, White, and other backgrounds, plus prefer not to say
- Disability: Whether the person has a physical or mental health condition lasting, or expected to last, 12 months or more that affects day-to-day activities
- Religion or belief: Including no religion, with a prefer not to say option
- Sexual orientation: Heterosexual or straight, gay or lesbian, bisexual, prefer to self-describe, prefer not to say
Template equality and diversity monitoring form
A clear, well-structured form makes it easier for employees to complete and easier for you to collect meaningful data. The template below covers the core protected characteristics and includes a "prefer not to say" option for every question. Adapt the language to fit your organization, but keep the framing voluntary and confidential throughout.
EQUALITY AND DIVERSITY MONITORING FORM
We want our workplace to be fair and inclusive, and we use equality monitoring data to understand whether we're achieving that. This form is entirely voluntary. Completing it helps, but there is no obligation to do so.
All responses are confidential. This form is kept separate from any application or assessment process, and the information you share will not be seen by anyone involved in any hiring or performance decisions. Data is used only in anonymized, aggregate form for reporting purposes.
1. Age
Under 25 / 25-34 / 35-44 / 45-54 / 55-64 / 65 or over / Prefer not to say
2. Sex
Male / Female / Prefer not to say
3. Gender identity
Is your gender identity the same as the sex you were registered at birth?
Yes / No / Prefer not to say
4. Ethnic group
Please select the option that best describes your ethnic background:
Asian or Asian British: Indian / Pakistani / Bangladeshi / Chinese / Any other Asian background
Black, African, Caribbean or Black British: African / Caribbean / Any other Black background
Mixed or Multiple: White and Black Caribbean / White and Black African / White and Asian / Any other Mixed background
White: English, Welsh, Scottish, Northern Irish or British / Irish / Gypsy or Irish Traveller / Roma / Any other White background
Other ethnic group: Arab / Any other ethnic group
Prefer not to say
5. Disability
Do you have a physical or mental health condition or illness lasting, or expected to last, 12 months or more that reduces your ability to carry out day-to-day activities?
Yes / No / Prefer not to say
6. Religion or belief
No religion or belief / Buddhist / Christian / Hindu / Jewish / Muslim / Sikh / Any other religion or belief / Prefer not to say
7. Sexual orientation
Heterosexual or straight / Gay or lesbian / Bisexual / Prefer to self-describe: [text field] / Prefer not to say
Thank you for completing this form.
Storing the data from an equality and diversity monitoring form
Equality monitoring data is sensitive personal data under UK GDPR. In the US, EEO-1 data is submitted directly to the EEOC and is subject to federal recordkeeping requirements. Employers covered by EEO-1 must retain personnel and employment records for at least one year.
It needs to be stored securely, with access limited to those who have a specific reason to see it. Recruitment application materials and monitoring forms should be stored separately. Data should be anonymized before analysis, and individual-level responses should not be visible to anyone assessing applications.
Your privacy notice should explain that this data is collected, what it's used for, how long it's kept, and who has access. If you don't currently have that language in your privacy notice, add it before you start collecting.
What happens next: Using the data
The gap between organizations that find this useful and those that don't usually comes down to whether anyone actually looks at what they've collected. Annual reporting means comparing your workforce profile against previous years and against external benchmarks for your sector. Are certain groups underrepresented at certain levels? Has that changed?
Some organizations publish an equality report. Others use the data internally to review shortlisting criteria, assess whether mentoring programs are reaching a broad range of employees, or identify where targeted recruitment outreach might be needed. There's no single right answer on what to do with it, but an annual form that sits in a folder unanalyzed is a waste of everyone's time.
One common oversight: completion rates vary by question, and particularly low completion on certain questions is itself informative. It can suggest that the question feels intrusive, that people don't trust the data will be handled properly, or that the form's introduction isn't doing its job. Worth tracking.
The admin burden of running recruitment processes
Equality monitoring forms are one item in a longer list of things that need to happen during recruitment: posting the role, screening applications, scheduling interviews, issuing offers, processing onboarding documents. The email volume that comes with that can be significant, particularly when several hiring processes are running at once.
Research published in Frontiers in Psychology in 2024 tracked email load as a workplace stressor and found it predicts strain over and above time pressure and interruptions combined. Anyone who's coordinated a hiring round while managing a full inbox will recognize that.
Fyxer organizes your inbox by priority and prepares draft replies based on what's come in, so the routine correspondence (application acknowledgments, interview confirmations, scheduling back-and-forth) takes less attention. If HR or recruitment email volume is a recurring problem, here's how Fyxer works. There's also more on managing email at work if you're thinking about it more broadly.
It's also worth having consistent templates across the full range of HR documents you issue regularly. Written statements of employment, disciplinary outcome letters, and equality monitoring forms that share the same level of care and structure are easier to keep up to date and less likely to be missing something when they're needed.
Frequently asked questions about equality and diversity monitoring
Is it a legal requirement to collect equality and diversity data?
For most private-sector employers in the UK, no. There is no blanket legal requirement to collect equality monitoring data. Public sector organizations subject to the Public Sector Equality Duty have stronger obligations around monitoring and reporting, but even there, the specific form that monitoring takes is largely a matter of judgment. Where the legal requirement does exist is in how you handle the data once collected: UK GDPR rules on sensitive personal data apply regardless of whether the collection itself is mandatory.
In the US, the picture is different. Private employers with 100 or more employees, and federal contractors with 50 or more employees and contracts of $50,000 or more, are legally required to submit EEO-1 reports annually to the EEOC.
What if someone refuses to complete the form?
That's their right. Participation is voluntary, and no one can be required to complete an equality monitoring form or penalized for not doing so. When someone declines, record a non-response rather than leaving a blank. High non-response rates across certain questions are themselves informative and worth investigating (as a trend, not on an individual basis), because they may indicate a trust issue with how the data is being handled rather than a problem with the question itself.
Should the form go out before or after the hiring decision?
Before, but handled separately. The standard practice is to include the monitoring form as part of the application process, kept in a separate system or folder from the application itself. The person assessing applications should never see the monitoring data. If your application process doesn't currently allow for that separation, issuing the form after a decision has been made is a reasonable alternative, though it reduces the usefulness of the data for analyzing shortlisting decisions.
Do we need consent under UK GDPR to collect this data?
Not necessarily. Consent is one lawful basis for processing special category data, but it's not the only one. For equality monitoring in an employment context, the more appropriate basis is usually Article 9(2)(b) of UK GDPR, which covers processing necessary for obligations in employment law. The ICO guidance on special category data is the relevant reference. What's required regardless of the lawful basis is transparency: your privacy notice must explain that this data is collected, why, how it's stored, and who can access it.
How long should we keep equality monitoring data?
There's no single prescribed retention period, but the UK GDPR principle of storage limitation applies: keep it only for as long as it serves the purpose it was collected for. For recruitment monitoring, a common approach is to retain anonymized aggregate data indefinitely for trend analysis, while deleting individual-level responses after the relevant recruitment round closes. For employee monitoring data, annual aggregation with deletion of individual responses after reporting is typical. Whatever you decide, document it in your data retention policy.
How many responses do we need before the data is meaningful?
There's no fixed threshold, but most analysts treat groups of fewer than five as too small to report on without risking identification of individuals. Some organizations apply a minimum of ten before including a category in reporting. For smaller employers, this can mean that certain protected characteristics produce data that's statistically unreliable on its own. In those cases, pooling data across multiple recruitment rounds or reporting periods is a practical approach, as is being transparent in any report that sample sizes are small and findings should be treated cautiously.
Can we ask these questions at the interview stage?
No. Equality monitoring questions should never be part of the interview process or asked by anyone involved in selecting or assessing candidates. The Equality Act 2010 places strict limits on pre-employment health and disability inquiries in particular. The monitoring form works precisely because it is separated from the selection process. Asking these questions in an interview context collapses that separation and creates direct legal exposure.
