FOI reference - FOI-351
Date - 17 February 2025
Request
This is an information request relating to Equality, Diversity and Inclusion (EDI) roles in your organisation.
Please include the following information for each of the following financial years; 2021 to 2022, 2022 to 2023, and 2023 to 2024:
- Total number of EDI staff employed for each financial year
- A breakdown of the staff employed including:
- the job titles
- the pay band associated with each role
Response
I confirm that we hold some of the information you have requested. However, some of the information you have requested is exempt from disclosure. I have set out the reasoning behind this decision in the below section.
I have set out the answers to your information request in the below table.
| Financial Year | Number of staff employed | Job Title(s) | Pay band |
|---|---|---|---|
| 2021 to 2022 | No staff but 1 contractor | EDI Lead | Not held* |
| 2022 to 2023 | 2 | EDI Advisor EDI Lead |
Exempt from disclosure, S40 FoIA |
| 2023 to 2024 | 2 | EDI Advisor EDI Lead |
Exempt from disclosure, S40 FoIA |
*As this is a contractor they do not sit within our normal pay grades. They are paid a rate of which is then invoiced to us via their agency.
Section 40 – Personal information
This information is exempt from disclosure under Section 40(2) of the FoIA. This is because the information constitutes personal data as defined in UK General Data Protection Regulations (UK GDPR). Disclosing this would not comply with the data protection principles, in particular the requirement for processing to be fair, lawful and transparent (Article 5 (1)(a)), as well as to comply with one of the lawful bases for processing in Article 6.
We have considered whether there is a lawful basis for processing/disclosing the information under Article 6(1)(f), on the basis that you may have a legitimate interest in such disclosure. However, in this instance, we believe disclosing the information would lead to individual employees being identified given the other information which is likely to be in the public domain and the limited number of employees in EDI roles. The specific role and pay band of individuals would be identified by such disclosure. In this instance, the legitimate interest in disclosure is overridden by interests of employee privacy.