1. Introduction
1.1
Brighton & Hove City Council is publishing the workforce disability pay gap voluntarily.
In the absence of a mandatory framework for reporting, Brighton & Hove City Council have chosen to replicate the regulations and measures used in gender pay gap reporting with some changes, to account for the different data sets, see 1.4.
Therefore, this report includes:
- the mean and median disability pay gaps
- the mean and median disability pay gaps including the gap for employees who have not disclosed a status
- the mean and median disability bonus pay gaps
- the proportion of disabled employees and employees who received a bonus
- the proportions of disabled employees and employees with no disability in each pay quartile
- the proportions of disabled employees, employees with no disability, and employees who have not disclosed a status in each quartile
1.2
The reporting data includes council employees who have self-certified their disability status as either ‘disabled’ or as having ‘no disability’ and were employed on 31 March 2024.
Apprentices, seasonal, temporary or casual employees are included if they fall within the reference period created by the snapshot date.
Mirroring the gender pay reporting regulations, the data excludes school-based staff.
1.3
Brighton & Hove City Council’s workforce equalities data is provided confidentially and voluntarily by individuals working for Brighton & Hove City Council.
Brighton & Hove City Council encourages its workforce to share their equalities data to understand the workforce profile and plan actions to address inequalities. Not all employees choose to share their details.
At the reporting date, 81% of the workforce disclosed whether they are disabled or have no disability. The remaining employees declined to specify.
1.4
The gender pay gap report compares 2 distinct groups – male and female – whereas disability recorded can fall into 2 broad categories: disabled, no disability, blank (not recorded) and unspecified (chose not to answer).
The way that gender is recorded for mandatory pay gap reporting means that there can be no blank or unspecified records.
In calculating the mean and median differences, we have chosen to focus on those who have specified their ethnicity to give the most precise view of the disability pay gap in Brighton & Hove City Council, as people with blank or undeclared disabilities could either be disabled, or non-disabled.
The blank and unspecified records are however reported separately in Brighton & Hove City Council's report at 3.4 and 3.5.2.
1.5
Brighton & Hove City Council publishes this information on its website.
1.6
This report relates to the snapshot date of March 31 2024.
2. Disability pay gap and equal pay
2.1
Pay gap reporting is different to equal pay. Pay gaps measure the difference in average hourly pay between different groups.
Unlike equal pay audits, which look at the difference in pay between people with different characteristics doing the same job, pay gap reporting looks at the wider picture across the workforce.
2.2
The disability pay gap is a measure of the difference in average ordinary earnings (excluding overtime) between employees with no disabilities and employees with a disability across the workforce.
It's expressed as a percentage of the earnings of employees with no disabilities.
Both the mean (average) and median hourly rates are reported.
2.3
The Equality Act 2010 makes it unlawful to discriminate (both directly and indirectly) against employees (and people seeking work) because of their disability.
An employer can be equal pay compliant and still have a disability pay gap.
The cause of a disability pay gap may not fall within the direct control of the employer and is likely to be due to other factors that impose a disadvantage on people with a disability without being explicitly discriminatory.
2.4
Brighton & Hove City Council supports the fair treatment and reward of all staff irrespective of disabilities or other characteristics.
This report sets out Brighton & Hove City Council's disability pay gap and provides a reference to Brighton & Hove City Council's action plan to tackle the gap.
3. Disability pay gap reporting
3.1
Mean and Median Pay Gap Reporting: Brighton & Hove City Council has a positive pay gap for both the mean and median gross hourly earnings.
3.2
The Mean (average) disability pay gap in hourly pay is 3.4%.
3.3
The Median (middle) disability pay gap in hourly pay is 2.7%.
3.4
The table below includes the headline pay gap measures, along with the gap between employees with no disability and employees who did not declare their status, both ‘declined to specify’ and ‘not known’.
| Group | Disabled | Not known | Declined to specify |
|---|---|---|---|
| No disability |
Gap between no disability and disabled groups: Mean: 3.4% Median: 2.7% |
Gap between no disability and not known groups: Mean: 4.1% Median: 5.8% |
Gap between no disability and declined to specify groups: Mean: 0.8% Median: 2.1% |
3.5
3.5.1
Salary quartile reporting is calculated by sorting employees by their average hourly earnings, from the lowest to the highest, then splitting them into four equal quartiles to show the proportions of disabled employees and employees with no disability in each group. Definitions of the salary quartile information are shown in Appendix A.
3.5.2
Salary quartile reporting, including employees who have not disclosed their status, is calculated by sorting employees by their hourly rate, from the lowest to the highest, then splitting them into four equal quartiles to show the proportions of disabled employees, employees with no disability, those who declined to specify their status, and those not known in each group.
| Quartile (Hourly earning rate range) | No disability % in Quartile | Disabled % In Quartile | Not known % in Quartile | Declined to specify % in Quartile |
|---|---|---|---|---|
| Lower Quartile (£7.49 to £14.90) | 71% | 7.4% | 18.6% | 2.9% |
| Lower Middle Quartile (£14.90 to £17.59) | 71.8% | 7.8% | 17.2% | 3.3% |
| Upper Middle Quartile (£17.59 to £21.18) | 76.3% | 7.3% | 13.7% | 2.8% |
| Upper Quartile (£21.26 to £89.59) | 76.9% | 6.5% | 13.6% | 3% |
3.6 - Bonus pay reporting
The council does not pay bonuses, as such no figures are reportable.
4. Supporting narrative
4.1
The council’s overall workforce disability profile based on this reporting data is 91.1% with no disability and 8.9% disabled. These figures exclude employees who have declined to provide their disability status (939).
4.2
3,938 employees are included in the reporting data. These employees held 4063 job roles in the pay period comprising of 3,817 contracted roles and 246 casual roles. As per applied reporting methodology, employees on less than full pay have been excluded.
4.3
The mean hourly rate of pay for disabled employees was £18.74. The mean hourly rate for employees with no disability was £19.40, this results in the reported 3.4% difference.
4.4
The median hourly rate of pay for disabled employees was £17.12. The median hourly rate for employees with no disability was £17.59, this results in the reported 2.7% difference.
4.5 - Salary quartiles
The % of disabled employees in each quartile is lower than the % of employees with no disability. This is similar to the workforce disability profile of 8.9% noted above. The highest % representation of disabled employees is at the lower and lower middle quartiles, with 9.5% of those in the lower and 9.8% in the lower middle quartile being disabled. Representation at upper middle quartiles (8.6%), and upper quartiles (7.7%) is lower.
4.6 - Men and women
The percentage of female employees who are disabled is 9.1%, and male 8.6%. The median disability pay gap for disabled female employees is 5.2% and for disabled men 0.5%. This means the median earnings of disabled female employees is 5.2% less than female employees with no disability. The median earnings for disabled male employees are 0.5% less than male employees with no disability.
4.7 - Pay of allowances
28.2% of the workforce in the snapshot pay period received an allowance in addition to their basic pay. Overall, 17.7% of all disabled employees received an allowance, compared with 29.2% of all employees with no disability in receipt of an allowance.
4.8 - Pay and grading
The council’s annual pay policy statement provides details of the council’s pay and grading arrangements and can be referenced via the link at Appendix B.
4.9
Further analysis on the workforce profile for disabled workers can be found in the annual workforce equalities report via the link at Appendix C.
5. How figures compare nationally
5.1
The Office of National Statistics (ONS) reported a UK median disability pay gap of 12.7% in 2023, a gap which has remained relatively stable since 2014. This is 10% higher than the BHCC reported median pay gap of 2.7%. The ONS data for 2024 is yet to be released.
Link to the ONS reported data can be found at Appendix D. It is important to note that employees of the council have self-certified their disability status whereas the ONS use the Government Statistical Service (GSS) harmonised “core” definition. Details on the identifiers used by GSS can be found on the link at Appendix E.
5.2
The ONS have reported that the UK 2023 disability pay gap was wider for men (15.5%) than for women (9.6%). The council’s disability pay gap for 2024 is 5.2% for disabled women, and 0.5% for disabled men.
6. Summary and actions
6.1
The council is confident that its disability pay gap does not stem from an equal pay issue. In 2010 the council introduced a new pay and grading system to ensure all roles are graded using a recognised job evaluation system to make sure individuals receive equal pay for equal work. In 2013 a new system of allowances and expenses was implemented to ensure consistency across the workforce.
6.2
The council’s disability pay gap shows that on average (by both measures) the earnings of employees who are disabled are less than employees with no disability, and this is similar to the national disability pay gap. The council has a positive disability pay gap because we have fewer disabled employees, and fewer disabled employees hold higher paid management and senior positions within the council than employees with no disability.
6.3
The council’s workforce is predominantly female making up 58% of the workforce data used for this reporting. The percentage of male employees who are disabled is (8.6%), this is slightly lower than female disabled employees (9.1%). Whilst the council workforce is largely female, and more female employees hold higher paid job roles than men, overall fewer women who are disabled hold higher paid roles than disabled men.
6.4
The council is committed to improving the diversity of its workforce to reflect its communities and disability forms part of our wider inclusion agenda. Being a fair and inclusive place to work is one of the five commitments of ‘Our People Promise’ made to employees. The work programme to deliver this promise, our co-created ‘Fair and Inclusive Action Plan’ has a comprehensive range of outputs to support the recruitment, retention and progression of disabled staff.
See Appendix F for a link to the Council’s Fair & Inclusive Action Plan.
Appendix A - Hourly Pay Definition for the purposes of calculating the mean and median hourly rates
Pay will include:
- basic pay
- paid leave, including annual leave, sick leave, maternity, paternity, adoption or parental leave (except where an employee is paid less than usual because of being on any such leave)
- area and other allowances
- shift premium pay
- pay for piecework
- bonus pay
It will not include:
- overtime pay
- expenses
Full-pay Relevant Employee Definition
“Full-pay relevant employee” means a relevant employee who is not, during the relevant pay period, being paid at a reduced rate or nil as a result of the employee being on leave. Employees who receive no pay at all during the relevant pay period, whether or not this is as a result of being on leave are excluded from the gender pay gap calculations. “Leave” includes:
- annual leave
- maternity, paternity, adoption, parental or shared parental leave
- sick leave; and
- special leave
Pay Quartiles
This calculation requires an employer to show the proportions of male and female “full-pay relevant employees” in four quartile pay bands. This is done by dividing the workforce (so far as possible) into four equal sections to determine the lower, lower middle, upper middle and upper quartile pay bands.
Where employees receiving the same hourly rate of pay fall within more than one quartile pay band, a relative proportion of male and female employees receiving that rate of pay was assigned to each of those pay quartiles.