In Canada, federally regulated workplaces (such as banks) with 100 employees or more are legally required under the Employment Equity Act¹ to collect and report on employee diversity demographic information for the following designated groups:

• Indigenous peoples
  
  

• Persons with disabilities
  
  

• Women
  
  

• Members of visible minorities

A note on appropriate language and terminology  
 
Aboriginal Peoples: The Government of Canada has adopted new terminology and no longer refers to Aboriginal peoples; the new preferred term is Indigenous peoples (First Nations, Inuit and Métis). Unless the context requires use of the term Aboriginal peoples as it appears in the Employment Equity Act or as part of a proper name, the federal Labour Program now uses the term Indigenous peoples. 
 
Visible Minorities: At the time of writing, the Government of Canada continues to use the term visible minorities, although it is considered outdated by many. The more commonly accepted and used term is racialized persons. 

Purpose

The purpose² of the Employment Equity Act is to ensure that all people in Canada have fair and equitable access to employment. It acknowledges that certain groups have faced (and continue to face) barriers to employment. By collecting, analyzing and reporting on diversity demographic data, a financial institution (FI) can identify underrepresented groups in its workforce and begin to work toward hiring and retaining qualified people within the above diversity groups.

It's important to note that employment equity does not mean hiring unqualified people to meet quotas.

People with disabilities, for example, are significantly under-employed. They are not unqualified and they want to work. But the fact remains that they face barriers to employment.

Definitions

The following definitions are taken from the Employment Equity Act and from the Employment Equity Regulations:³

Persons with Disabilities

Persons with disabilities are “persons who have a long-term or recurring physical, mental, sensory, psychiatric or learning impairment and who:

• consider themselves to be disadvantaged in employment by reason of that impairment, or
  
  
• believe that [an] employer or potential employer is likely to consider them to be disadvantaged in employment by reason of that impairment, are persons whose functional limitations owing to their impairment have been accommodated in their current job or workplace.”

Employee

Employee means a “person who is employed by the employer but does not include a person employed on a temporary or casual basis for fewer than 12 weeks in a calendar year.”

  

Data collection requirements

The following information is based on the Employment Equity Act:⁴  

• Employers must conduct a workforce census or survey. To do so, they must provide each employee with a self-identification questionnaire that asks if the employee identifies as a member of one or more of the designated groups (listed above).
  
  
• If an employer becomes federally regulated, they are required to collect data on the representation of women only in the first year of reporting.
  
  
• The employer must inform each employee that a person may be a member of one or more designated group(s). This information must appear on the questionnaire or in a notice that accompanies the questionnaire. The questionnaire must also have the following features:
  
  
  • A means of identifying the employee who returns the questionnaire (i.e. by 
 name or employee number).
    
    
  • The definitions of Indigenous peoples, persons with disabilities, women and 
 members of visible minorities, as they appear in the Act.
    
    
  • An indication that responding to the questions is voluntary.
    
    
  • An indication that the information collected is confidential.
    
    
  • An indication that the employer will only use the information or disclose it to 
 other persons within the organization to carry out its obligations under the Act.
    
    
• The employer may require that employees return the questionnaire with the option to respond to all, some or none of the questions or to return a blank survey.
  
  
• The questionnaire may include additional questions relating to employment equity or broader diversity identity (e.g. sexual orientation, gender identity or accommodations required for persons with disabilities).
  
  
• The employer must keep the workforce survey results up to date. This requires:
  
  
  • Providing a questionnaire to newly hired⁵ employees, as well as to 
 employees who want to complete a new questionnaire.
    
    
  • Adjusting results to reflect the new responses and to consider members of 
 designated groups whom the employer terminated.⁶
    
    
• Employers must establish and maintain the following records:
  
  
  • A copy of the self-identification questionnaire provided to employees.
    
    
  • Each employee’s designated group membership, as applicable.

Going the Extra Mile!

As a federally regulated financial institution, you are required to collect diversity demographic data. But have you considered opportunities to make this process even more inclusive and efficient?

Beginner - Just Starting?

• Consider your diversity data collection requirements and the systems and resources you need to put in place from the start.
  
  
• Start early so you have time to collect and analyze the data before you submit your report.
  
  
• In the communications and the questionnaire, include language that appears in your EDI strategy. For example, restate your commitment to a welcoming, inclusive, accessible and respectful workplace for all diversity identities.

Intermediate - Been Doing This for a While?

• Get feedback on the employee experience regarding annual diversity data requests.
  
  
• How accessible is the annual questionnaire for new hires or if existing employees want to update their information?
  
  
• Consider a review of the end-to-end data collection process and experience to identify potential areas for improvement. Examples might include the contextual setting, asking broader diversity identity questions, improving access to the survey or data input and analysis.
  
  
• Expand your diversity data collection beyond the required four designated groups to include additional groups, e.g. employees who identify as members of the 2SLGBTQQIA+ communities.
  
  
• Begin collecting data at the application/interview stages if you aren’t already doing so. This will allow you to identify at what point employees with disabilities (or other diversity identities) were screened out and are no longer considered for employment. It can also show you where your efforts are more successful.
  
  
• Conduct an equity, diversity, inclusion and accessibility audit of your financial institution via an external consultant. By reviewing all human resource policies and processes (systems and behaviours) and gathering anecdotal evidence from employees, you can further complement the data you collect and ensure a more accurate and robust picture of your efforts.

• Tool #4: Onboarding and Retention
• Tool #6: Diversity Demographic Reporting