Disability, mental health and wellbeing reporting

14 Feb 2019 By Ben Power

Ben Power explains employers’ obligations around the new framework for voluntary reporting on disability, mental health and wellbeing

In November 2018, the government published a new framework intended to support employers to record and report voluntarily on disability, mental health and wellbeing in the workplace. This follows the Thriving at Work Review by Paul Farmer and Lord Dennis Stevenson in 2017, which recommended that employers voluntarily report more information about their actions on workplace mental health. 


The government has worked with large employers and third sector organisations to produce the framework, which takes the form of two pages of guidance for employers. One page looks at reporting on disability while the other deals with reporting on mental health and wellbeing. 

The framework is aimed at large employers (those with over 250 employees) across all sectors – public, private and voluntary. It can also be used by smaller employers who want to drive greater transparency in their organisation. How enthusiastically small employers will take up the framework – which may be perceived as just another bureaucratic task to take up scarce resources – remains to be seen. 

The framework is voluntary, there is no penalty for not using it, and as gender pay reporting demonstrates (where so few organisations published voluntarily, legislation was eventually introduced) until there is a legal requirement to disclose internal data, many employers are unlikely to do so. 


Various potential benefits of greater transparency are given in the framework document, including:

  • better employee engagement and retention, leading to increased productivity, better performance and fewer sickness absences days;
  • accessing a wider pool of talent and skills through disability-friendly recruitment;
  • better serving and connecting with disabled customers and communities;
  • facilitating open and supportive conversations with employees about disabilities and health conditions to enable them to remain in work and achieve their potential.

What does the framework say?

The framework is not prescriptive about the information to be collected or how it is reported. Instead it sets out the principle that the data voluntarily shared should be accurate, complete and provide context.

The disability reporting recommendations are divided into parts A and B. In part A, the suggestion is that a narrative on the organisation’s recruitment and retention of disabled people should be provided. Examples given of the sort of information which should be reported include: 

  • the organisation’s policies on the recruitment and retention of disabled people;
  • support offered to employees with specific disabilities;
  • progression and pay of disabled employees;
  • workplace adjustments; and
  • the role of networks and support groups.

In part B, it is suggested employers report on the percentage of employees who consider themselves disabled. This data could be collected through anonymous staff surveys or through employees updating their own HR records. The recommended words to use for the question asked of staff is also given.

The section of the framework on mental health and wellbeing follows a similar structure. Part A suggests a narrative to explain how the organisation supports the health and wellbeing of employees, including information about:

  • employee take-up of mental health support;
  • training offered to employees related to mental health;
  • the percentage of employees who are comfortable disclosing mental health.

Part B lists recommended questions as a starting point for measuring employee wellbeing, e.g. ‘How happy did you feel yesterday?’ and ‘How satisfied are you with your job?’.

The framework document also contains some interesting real-life case studies from employers such as Channel 4 and Thames Water.

Where should employers report their data?

This is a decision for the employer. It suggests an organisation’s annual report may be the most appropriate place. When publishing the information, the questions asked and the collection methodology should be stated.

Data protection issues

The framework is light on any data protection guidance, other than stressing the importance of being transparent with employees about data use, handling and storage. Even with anonymised data, issues can still arise. Clearly the data reported will be sensitive as it relates to health, so extreme care to avoid unauthorised disclosure and adequate security measures should be put in place. Privacy policies should be reviewed to ensure this type of voluntary reporting is covered and a retention policy regarding the data collected should be put in place. 

We may still be some way away from the government compelling compliance as far as disability and mental health data reporting is concerned, and the latest guidance should be seen as a first step. However, building a more inclusive society is firmly established on the government’s agenda, and it believes transparency and reporting are effective levers to drive the necessary cultural change needed to achieve this. 

Ben Power is founding partner of Springhouse Solicitors

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