Count me in! – Detailed case studies

Mount Saini Hospital 

Founded in 1923, Mount Sinai Hospital (MSH) is a large patient care, teaching and research hospital affiliated with the University of Toronto. Since 2007, Media Corp Inc. has named MSH one of Greater Toronto’s Top Employers.

MSH’s vision is to deliver and model world-class proactive health care. The hospital also seeks to be a national leader in all of its diversity and human rights programs, and to have a staff team that reflects the diverse patients they serve. In November 2006, MSH approached an external consultant to help them learn more about their staff in terms of characteristics like race, ethnicity, disability, sexual orientation, age, gender, education, languages and place of residence. MSH was the first health care institution in Ontario to do such a broad workforce census.

Why consider collecting data?

Some factors that led MSH to do this census included:

  • A desire to provide equitable access to care that took into account a range of culture and language needs given that MSH belongs to the most socially diverse urban Local Health Integration Network (LHIN) in Toronto[1]
  • Concerns that some groups were underrepresented in upper management jobs
  • A desire to understand the makeup and needs of its workforce, measure the success of its diversity efforts, and apply this understanding in future plans
  • A history of serving members of society who faced discrimination and exclusion
  • A belief, strongly supported by the President and CEO, that this was the right thing to do.

Goals of the workforce census

The key goals of the workforce census were to help MSH:

  • Be a great place to work, teach, research and volunteer, where patients could get the best care and staff could reach their potential in an environment that was inclusive and free of discrimination
  • Understand the make-up of the MSH workforce and compare it to the external population and patient base
  • Understand the needs of the MSH workforce
  • Address the needs of the patient population and broader community by developing the MSH workforce through recruiting new employees and succession planning
  • Deliver and model world-class proactive health care
  • Be a national leader in all of its diversity and human rights programs.

Challenges and planning

MSH had to consider a number of challenges when planning how best to collect the data:

  • The need to get support from many different stakeholders across the organization
  • The strong sensitivity to the information being asked, its use and confidentiality 
  • The desire for anonymity by healthcare workers because of strong concerns about privacy and fear of discrimination, especially based on sexual orientation or psychiatric disability 
  • The logistical issues of surveying 5000 staff, including many who worked shifts and did not regularly use a computer
  • The resource constraints of trying to reach 5,000 staff members and make sure that the highest number complete the survey in the time given.

Preparing for the workforce census

To address the above challenges, MSH took the following steps before launching the workforce census:

For the past seven years, MSH’s Diversity and Human Rights Office (DHR), under the leadership of the Hospital’s Diversity and Human Rights Committee and Marylin Kanee, MSH’s Diversity and Human Rights Advisor, had done extensive work to advance human rights issues and foster an organizational culture of inclusiveness and equity, which earned the trust and support of senior leaders, particularly the President and CEO. This trust and support was a key element as MSH prepared for the survey. Activities before the survey was launched included:

  • Training, resolving complaints, developing policies, and reviewing systems and procedures[2]
  • Involving all departments in creating the census, including DHR, Human Resources, Occupational Health and Safety, Organizational Development and Volunteer Services
  • Working with a steering committee at all stages
  • Making the census voluntary, anonymous and confidential
  • Getting buy-in from union representatives and physician leaders early in the process
  • Working with managers and recognized role models in the hospital as key communicators
  • Inviting representatives of other organizations that had conducted workplace surveys and audits to speak about the benefits achieved
  • Involving the communication team in all meetings and vetting of communications materials
  • Identifying a two-week time period during which the majority of staff were typically available as the appropriate time to complete the census
  • Designing an extensive communications strategy that included posters, pay stub inserts, newsletter ads, staff letters from the CEO and other Hospital leaders, and frequently asked question handouts.

Administering the workforce census

  • The MSH workforce census was launched from May 14, 2007 to May 27, 2007, with an extra week added for staff to complete the census
  • The census consisted of 50 survey questions and took, on average, 7-20 minutes to complete, depending on English language fluency and other factors
  • Staff could fill out a paper copy, or use laptop computers that were made available at key locations throughout the hospital
  • DHR staff and committee members were in the lobbies every day with laptops and paper copies of the survey for staff to complete manually or on-line. They also were available to answer any questions or concerns, and to assure people that the census was confidential and anonymous. Each unit and department in the hospital was similarly approached with laptops, hard copies and refreshments in hand
  • Staff who filled out the census were eligible to win prizes if they filled out a ballot and dropped it off in a drum in the main lobby
  • An external consulting company administered the census, collected and stored the data, and reported the overall results to MSH. No one at MSH saw the individual responses.

Some key results

  • The return and response rate was 55%;[3]  the sample size was 2475 employees;[4] 70% of employees completed the census on-line
  • General census statistics for the Toronto Census Metropolitan Area were used as a baseline against which internal MSH results were compared against the external population[5]
  • Overall, the MSH workforce fairly reflected the community it serves.

For example:

  • staff represent more than 100 culture and ethnicity categories[6]
  • 57% can speak a language other than English
  • 38% are members of racialized groups[7]
  • 6% identified as having a disability[8]
  • 5%[9] identified as gay, lesbian, bisexual, questioning[10] or Two-spirited[11] and 1.1% of persons identified as “transgendered” (GLBTTQ)

As well, one-third of foreign-trained immigrants were less likely to be using their credentials in their jobs (21%) than people educated or born here (34%). And while there is much diversity in the lower and supervisory staff levels, diverse groups (especially racialized persons) were underrepresented in upper management positions.

Acting on results of the workforce census

  • MSH widely reported the results of the workforce census to staff in many formats including: in its internal newsletter Inside Sinai; on MSH’s intranet; through informational employee forums in the hospital; and via workshops conducted with managers and senior leadership
  • MSH is using the data to find where there are gaps between the make-up of its existing workforce and that of the City of Toronto
  • Targeted programs, policies and initiatives aimed at supporting diversity throughout the organization are being developed to identify and address barriers.

Some examples are:

  • A new Fair Employment Opportunity Policy on how to conduct fair recruitment and hiring. MSH is integrating human rights and diversity competencies into hiring, performance appraisals and succession planning.
  • For employees facing barriers in having their credentials and qualifications recognized, MSH is looking at ways staff and volunteers can have them acknowledged. MSH has partnered with the Toronto Region Immigrant Employment Council (TRIEC) to provide mentors to internationally-trained professionals and is building relations with organizations that find employment for people with disabilities and recent immigrants
  • To improve access for people with disabilities, MSH has conducted focus groups with patients to better understand their experiences, and is implementing Accessibility for Ontarians with Disabilities Act (AODA) Customer Service Training
  • To promote respectful treatment of “GLBTTQ” members of the hospital community, the hospital developed an anti-homophobia/transphobia communication campaign and posters and brochures promoting “equity is good for your health.”
  • The next MSH workforce census is planned for 2011.

Best practices

  • Having strong leadership that promotes a culture of respect, inclusion and equity
  • Having the support and testimonials of recognized role models in key constituencies across the organization
  • Making people and resources available to develop and run an effective communications strategy
  • Making the census as easy and accessible to complete as possible. For example, offer accessible print and on-line format options in easy to reach places throughout the organization
  • Offering creative incentives for taking part (such as refreshments and prizes)
  • Giving people a chance to speak about their questions and concerns
  • Following-up and communicating the census results to staff
  • Regardless of the participation rate, use the census as a valuable education process to learn about the organization and raise awareness.

Lessons learned

  • Making sure that the census has a manageable number of clear questions[12]
  • Anonymity of respondents limited the ability to identify gaps and track progress in units and branches[13]
  • Having some understanding of employment equity terminology and processes is helpful
  • Organizations lacking the internal capacity or ability to review the raw data results should consider investing in a respected external consultant to do the analysis.


[1] MSH belongs to the Toronto Central LHIN. This LHIN serves some of Ontario’s lowest-income neighbourhoods and many of Ontario’s high-income, high-education neighbourhoods. Residents come from over 200 countries and speak over 160 languages and dialects. There is a high concentration of people who are homeless and living with serious mental illness. There are also high rates of lone-parent families, people living with HIV/AIDS, unemployed youth, and seniors living alone. See Mount Sinai Hospital, A Framework for Creating Health Equity In the Toronto Central LHIN (2005) at 1 online: www.mountsinai.on.ca [Health Equity Report].
[2] DHR had been conducting internal focus groups to assess the experience of various groups within the MSH work environment, and a community consultation with 10 distinct cultural communities that have traditionally experienced barriers to healthcare. MSH also offered targeted policies and programs for underserved or underrepresented populations, including a summer mentorship program for Black and Aboriginal students, a clinic for HIV-related concerns, and a study of cancer screening for women with mobility disabilities. Marylin Kanee in telephone interview with Commission staff on March 23, 2009 [MSH Telephone Interview].
[3] This rate decreases to 52% if persons on leave are factored in.
[4] The MSH sample size on which the analysis was based includes MSH staff, staff physicians, principal investigators, volunteers and Lunenfeld employees. Health Equity Report, supra note 1 at Appendix B.
[5] Statistics Canada compiles a range of statistical tables by Metropolitan Area across Canada, including Toronto, based on immigrant population, income, language and other indices. A Metropolitan Area is defined as a large urban area with a population of 100,000 or more, based on the previous census. Statistics Canada, Tables by Metropolitan Area online: www40.statcan.ca/z01/cs0007-eng.htm.
[6]“Most notably with Chinese (10 per cent), Jewish (9 per cent), Filipino (6 per cent), West Indian (6 per cent) and English (6 per cent). Health Equity Report, supra note 1 at Appendix B.
[7] In Appendix B of its Health Equity Report, MSH describes “racialized” as “…a term that expresses race as a social construct rather than perceived physical traits.” Ibid.
[8] Of those employees who identified as having a disability, 90% said they had a disability that was not visible, and 53% had a chronic illness. Ibid.
[9]  “This percentage reflects the response in a study conducted by the Canadian government but does not reflect the GLBQ2 population of Toronto, which is expected to be at least 10 per cent. Under-reporting is possibly the result of privacy concerns and fear of discrimination.”  Ibid.
[10] Questioning was defined in the Census as “unsure of one’s sexual orientation.”
[11] Two-Spirited was defined as “Aboriginal people who identify as gay, lesbian, bisexual, transgendered, transsexual or intersex.”
[12]  “Next time I would like to shorten the number of questions to 20 and focus on demographic questions relating to race, ethnicity, sexual orientation, etc...The responses to other questions, such as staff activities, were interesting but not as necessary. I would also like to simplify some questions to avoid any possible confusion that may result. MSH Telephone Interview, supra note 2.
[13] Conducting the workforce census for the first time gave employees the opportunity to become comfortable with the concept and develop trust around the organization’s use and handling of the census data. I hope that the next time we do the census, employees may be more open to providing their employee numbers.” Ibid.

 

KPMG Canada

KPMG LLP (KPMG) is the Canadian member firm affiliated with KPMG International, a global network of professional firms providing audit, tax and advisory services to clients in over 140 countries. KPMG in Canada has 33 offices nationally and over 5,000 professional staff.

KPMG is committed to creating and supporting a diverse and inclusive workplace culture that respects and values peoples’ differences. KPMG Canada has won many awards for its efforts. For example, for the past two years, KPMG has been the only accounting firm, among the top four accounting firms in Canada, to be named one of the Best Employers for New Canadians and Canada’s Best Diversity Employers.

The Pulse Survey

In 2001, KPMG introduced the Pulse survey, an annual employee engagement survey. This replaced Interchange, an employee engagement survey that has existed since 1996. The Pulse survey includes 16 statements (out of approximately 90 questions overall) that relate to diversity. Some of the questions are designed to measure and track how people perceive and experience the workplace. 

The Diversity Profile Tool

In June 2009, KPMG rolled out the Diversity Profile Tool (DPT). This new and effective automated process allows KPMG to collect specific demographic data on its employees. This self-identification tool replaces the old Employment Equity (EE) survey that all KPMG employees had to complete during their orientation, or “on-boarding process,” because of KPMG’s commitment to the Federal Contractors Program (FCP).

The DPT has 14 questions; including four mandatory questions on membership in the four designated groups required under the FCP, and 10 additional questions relating to: cultural background and national heritage, religion and faith, primary language, marriage and parental status, sexual orientation, and foreign trained professional status.

Why consider collecting data?

Various factors motivated KPMG to collect employee information using the Pulse Survey, including:

  • A desire to monitor and measure the impact and success of KPMG’s diversity initiatives and programs, and to identify gaps that need to be addressed - “We can’t monitor what we can’t measure.”
  • A commitment to ensuring its leaders were accountable for addressing the outcomes of the Pulse Survey and taking appropriate action.

Factors that motivated KPMG to collect employee information using the DPT included:

  • A need to make sure KPMG complies with the FCP and the Employment Equity Act. This allows KPMG to continue doing business with the federal government. This has represented a fair amount of business for the firm in the past, and hopefully more going forward.
  • A desire to enrich both KPMG’s national diversity strategy and its people programs – the information collected will make sure that KPMG continues to target and meet the needs of its people as employees
  • A desire to better reflect the changing needs of KPMG’s people and create a workplace that complies with legislation, but is also truly inclusive. The earlier process allowed KPMG to collect data on four specific groups only, and did not provide enough detail for the information to be valuable to the firm.

Goals of the workforce census

The overall goals of the Pulse Survey and the DPT are to help KPMG:

  • better target its diversity initiatives
  • better monitor and shape its diversity programs
  • better engage its people
  • create and support a diverse, welcoming and inclusive work culture that respects and values peoples’ differences
  • be an employer of choice.

Challenges and planning

KPMG had to consider a number of challenges when planning how best to collect the data using the Pulse Survey:

  • the need to develop statements that can be tracked and measured every year
  • the technical limitations of tracking intersections of employees’ identity using the Pulse Survey
    • For example, the Pulse Survey can tell KPMG how women and visible minorities will respond to the statement, “Racist comments are not tolerated at KPMG,” but it cannot show how women who are visible minorities respond to the same statement.
  • the difficulty of not being able to track certain groups of employees by office, because people are not self-identifying, or because there is not a large enough sample size in each office
  • For example, KPMG’s overall firm numbers may show that there are issues or challenges a particular group, such as Lesbian, Gay, Bisexual, and Trans-Identified (LGBT) employees, are facing. It may, however, be difficult to determine what office is facing these challenges because there may not be a large enough sample of LGBT employees in each office and/or some employees are not self-identifying as LGBT.

KPMG had to consider a number of challenges when planning how best to collect the data using the DPT:

  • the need to develop a strong business case to get buy-in from senior leaders, particularly the partners, associate partners and KPMG’s “People Leaders”
  • the support of a number of other stakeholders in the organization that would be responsible for playing a key role in developing, implementing, delivering and ensuring quality of the DPT, like the Human Resources Services, Information Technology, Communications and Legal Teams
  • concerns about the use, privacy and confidentiality of the information being collected.

Preparing for the Pulse Survey and the Diversity Profile Tool

To address the above challenges, KPMG took the following steps before launching the Pulse Survey:

  • Made diversity a strategic business priority, and set goals that showed a serious commitment to creating and supporting an organizational culture that respects and values peoples’ differences.
  • Worked closely with an external provider and subject matter expert in the area of employee engagement to create statements that could be tracked over the long term and allowed the respondents to provide feedback that was relevant to KPMG’s work.
  • Collected and analyzed qualitative data gathered through such methods as focus groups, to track intersections of employees’ identity and understand how people can experience or see the workplace differently.
  • Used different approaches to track and address issues that affect groups that may not self-identify and/or may not have a large enough sample size. Approaches included looking at overall firm numbers and setting up a mentoring program. Depending on the nature of the issue and other factors, KPMG may also address concerns through: an appropriate KPMG network (e.g. Pride@kpmg), a national taskforce (e.g. National Aboriginal Taskforce), or KPMG’s local and national Diversity Councils.

Before launching the DPT, KPMG took the following steps:

  • Had the Diversity, Equity and Inclusion team coordinate the DPT initiative, which included identifying and involving all key decision-makers/stakeholders in planning, implementing and communicating the DPT.
  • Piloted the DPT in early 2009 with a national human resources group. This group helped identify potential issues, confirm positive elements of the initiative, provide valuable feedback to enhance the survey, and create a draft frequently asked questions (FAQs) document
  • Consulted other human resources staff who provided constructive input used to draft the final FAQs document circulated to staff and leadership.
  • Identified champions within the organization to be key communicators and to promote the importance of completing the Diversity Profile.
  • Vetted all messaging through Communications, the Diversity, Equity and Inclusion Team, and the Chief Human Resources Officer (CHRO) before circulating to leadership and staff.
  • To address privacy and confidentiality concerns, involved both internal and external legal counsel in preparing the demographic data collection questions, to make sure KPMG was meeting all legal requirements. Respondents were assured that all responses were anonymous.
  • Conducted an extensive communications plan so that respondents understood key points such as why the demographic questions were being asked and how employees benefited from taking part.
  • Addressed privacy and confidentiality concerns, via the communications strategy and detailed FAQs, which highlighted that:
    • employee responses will only be reviewed to identify overall population data and to identify trends
    • KPMG’s aim is to create initiatives that will positively support all staff
    • no one person will be singled out because of their responses
    • Diversity Profile information would be encrypted and stored in a Canadian database, subject to Canada’s Privacy Act, and could not be accessed by anyone outside of KPMG
    • both internal and external legal counsel had been consulted to make sure that KPMG was meeting all legal requirements
    • employee profiles will be password protected with a password that each employee creates, and no one will have access to employees’ passwords
    • employee profiles will be completely confidential and will never be shared with Performance Managers or any unauthorized persons
    • the Management Committee has authorized the Director of Diversity to be the only firm member with access to the Diversity Profile information, and the Director must abide by Canada’s privacy laws
    • one member of the Human Resources Services Team (HR Services Team) will help create reports on the profile data, but will not have access to the name associated with each profile
    • individual employees can access and update their Diversity Profiles at any time.

Administering the Pulse Survey and the Diversity Profile Tool

Pulse Survey:

  • The Pulse Survey is a voluntary employee engagement survey that is conducted every year, usually in November or early December.
  • The survey contains 16 statements (out of approximately 90 questions overall) that relate to diversity. There are also eight demographic questions based on Code grounds and non-Code grounds.
  • Employees and partners are advised that it is not mandatory to complete the Pulse Survey, but they are strongly encouraged to fill it out.

Diversity Profile Tool:

  • The DPT consists of 14 questions, including four mandatory questions on
  • membership in the four designated groups required as part of the FCP, and 10 other questions relating to a number of areas, including cultural background and national heritage.
  • Respondents are told that it is mandatory for all employees and partners to complete the survey. Respondents can choose not to answer a question but must submit their profiles, even if they opted out of answering some or all of the questions.
  • In June 2009, KPMG’s CHRO launched the DPT by sending an e-mail to the partners, associate partners and People Leaders. The e-mail outlined the launch of the DPT, its importance, and the benefits of encouraging staff to complete it. Detailed FAQs were included to help management address questions from staff, like how their privacy and confidentiality would be protected.
  • A week or two after the CHRO’s e-mail to senior leadership, the National Director of Diversity, Equity and Inclusion sent a similar e-mail and detailed FAQs to all staff.
  • The HR Services Team was available to respond to any questions or concerns, and used a detailed script to help them do so.
  • If the HR Services Team could not answer a question or an employee wanted to provide feedback about the new DPT, they were advised to contact members of the Diversity, Equity and Inclusion Team directly. Staff could also send questions, comments or concerns to KPMG’s diversity mailbox.
  • Employees who did not complete their Diversity Profiles would get automated e-mail reminders.
  • The DPT is now an ongoing part of the orientation process.

Some key results

Pulse Survey:

  • Last year’s return and response rate was 77%; the sample size was 5,144 employees.
  • Everyone throughout the firm responded 12-18% higher to the statement, “My future career opportunities look good here at KPMG, overall."
  • Many groups are feeling more positive in terms of gender and visible minority stereotypes being effectively addressed.
  • KPMG has seen that creating a welcoming, inclusive environment is enabling employees to bring more of themselves to work, resulting in higher productivity and increased loyalty to the firm.
  • KPMG has also seen that its efforts to embed diversity in the business and address work-life effectiveness, through initiatives like Fitness Memberships, flexible work programs and reflection rooms, translate into lower absenteeism and sickness – and healthier employees.
  • KPMG has learned that if it effectively promotes programs, more people will access and benefit from them (e.g. the Sabbatical Leave program). This is particularly important when considering that the suite of programs and benefits offered at KPMG is one of the key reasons why people join the firm.
  • Overall, the results say that KPMG has to continue the momentum of the work it is doing.

Diversity Profile Tool:

  • The sample size was 5,144 employees. Because the DPT was recently launched, KPMG does not have key results to report back on and cannot confirm a return and response rate. KPMG is still sending follow-up e-mails.
  • KPMG anticipates being able to report back to staff on key results by the end of the fiscal year.
  • Based on available data from the last Canadian Census, KPMG’s Toronto offices represent the communities they serve – having higher than average representation of measured groups.
  • The DPT is able to adequately gauge KPMG’s demographics. The information collected is still being analyzed to provide an understanding of the current composition of the national workforce, among other insights. 

Acting on the results of the Pulse Survey

  • The Diversity, Equity and Inclusion Team deliver results through presentations or information meetings with Partners, People Leaders and each business unit leader, who in turn decide how to communicate results to their staff.
  • In many cases, KPMG’s programs were created in response to employee feedback, such as the Pulse Survey results.
  • Depending on the nature of an issue of concern and where it is based, KPMG will tailor interventions accordingly. Examples include:
  • holding focus groups with particular groups to better understand and address issues
  • conducting professional development and/or diversity training
  • connecting people to KPMG’s professionals clubs/networks (e.g., Women’s Interchange Network)
  • setting up a Diversity Council in a particular office or the region to help make sure that local diversity issues are addressed and solutions are implemented and leveraged within the business units, consistent with KPMG’s national strategy.
  • The following are examples of some KPMG programs and initiatives that have been developed and implemented as a result of employee feedback, such as the Pulse Survey results:
    • To help and support new Canadians who are existing or potential employees, KPMG supports TRIEC’s mentoring partnership program. KPMG also recently partnered with the newly formed Edmonton Region Immigrant Employment Council (ERIEC) and Immigrant Employment Council of British Columbia (IEC-BC).
    • KPMG has set up reflection rooms in its major offices to give people a tranquil space where they can pray, reflect and meditate.
    • KPMG’s Reciprocal Mentoring Program connects its senior leaders with employees of diverse backgrounds and varying levels. Through one-on-one, face-to-face interactions, employees receive invaluable professional development advice while leaders gain perspective on diversity issues and experiences in the workplace that differ from their own. Participants also contribute to developing strategies for creating a more inclusive work environment, and the program enhances communication and relationship building among staff.
    • To remove barriers to advancement and diversify the workforce, KPMG has introduced a program to help increase the number of women and visible minorities in partnership positions. KPMG is also working with its national recruiting team to ensure diverse hiring practices.
    • In 2008, the firm created the national KPMG Aboriginal Task Force. Headed by an Aboriginal partner, the Task Force was created to raise awareness of Aboriginal issues while supporting and advancing the needs of Aboriginal employees. The Task Force also helps to implement a strategy for recruiting and retaining Aboriginal employees by increasing representation of Aboriginal peoples in the accounting industry as a whole, and in finance and accounting post-secondary programs.
    • As part of its Aboriginal Inclusiveness Strategy, KPMG is one of the first corporations to take part in a pilot Aboriginal Youth Mentoring Program aimed at encouraging Aboriginal youth to complete high school and pursue careers in accounting. KPMG's Hamilton office has partnered with the Martin Aboriginal Institute – a project of the former prime minister, the Right Honourable Paul Martin – and the Canadian Institute of Chartered Accountants for this pilot project.
    • People Matters is a firm-wide initiative that focuses on designing people practices to support KPMG’s goal of being a great employer. Programs have been created to help employees manage different aspects of their life and find work-life effectiveness so they can remain fully present at work. One example is Backup Child and Dependant Care, which gives all employees the availability of emergency back-up care when regular care arrangements for children and elderly dependents are unavailable.
  • Data collected from the Pulse Survey allows KPMG to set targets for achieving change to improve the organization and make it more inclusive.
  • All of KPMG’s business unit leaders are accountable for addressing diversity concerns in their unit by tracking, comparing and evaluating all business units’ Pulse Survey results, year after year.
  • KPMG is also developing a diversity report card that will include key performance indicators based on such factors as the Pulse Survey results, retention rates, and the community involvement of a business unit.

Best practices

  • Collecting information through the Pulse Survey, on an annual basis, has helped KPMG: track and monitor its progress; recognize that “you can’t monitor what you don’t measure”, be proactive rather than reactive, and ensure that its programs are effective and of benefit to its employees.
  • Gathering data through the Pulse Survey, on an annual basis, has helped KPMG further segment its Pulse Survey results and identify gaps, trends, and issues of concern.

Lessons learned

  • Unless people identify themselves (e.g. as a visible minority or Aboriginal person), further effort and creativity is required to track and monitor a particular group of interest.
  • When organizations are developing statements/questions for an annual survey or other tool, they must be certain that the statements/questions are ones that they want to be asking over the long term - they must plan and think through carefully.
  • It is okay to modify statements/questions now and then, but modifying them too much can prevent an organization’s ability to track a response if there’s too much variance between the original statement/question and the modified one.
  • Tracking the intersections of peoples’ identity and how they can experience or see the workplace differently would be helpful.
  • When necessary and able, an organization should supplement numbers with qualitative data collection methods. Such an approach can often provide a better understanding of an issue and how to address it.
  • If a concern comes to the attention of a business unit and changes are put in place, the business unit should not expect change overnight. Some issues can be resolved that quickly, but in most cases, it is a process to see an organizational culture change. You may see a shift in the following year or it may take longer than that.

Keewatin-Patricia District School Board

Ontario’s New Approach to Aboriginal Affairs commits the government to working with Aboriginal leaders and organizations to improve education outcomes among Aboriginal students.[1] The challenge for the Ministry of Education (MOE) in helping Aboriginal students and assessing progress “was the absence of reliable student-specific data on the achievement of First Nation, Métis and Inuit students across Ontario.” [2]      

In March 2003, MOE provided funding to support an Aboriginal student self-identification policy research pilot project, an initiative of Northern Ontario Education Leaders (NOEL) and Northern Aboriginal Educational Circle (NAEC). The task of self-identification policy development was assigned, as a shared responsibility, to two boards in Kenora, Ontario, which had sizable Aboriginal student populations – the Keewatin-Patricia District School Board (KPDSB) and the Kenora Catholic District School Board (KCDSB). The intent was that the two Directors of Education would develop a policy process and product that could eventually be used by other NOEL boards to give the MOE reliable data on Aboriginal students.

As a result of the NOEL pilot project, six school boards in north-western Ontario have developed a self-identification policy. With these policies in place, “these boards are able to focus their efforts and resources on strategies for improving Aboriginal student achievement and evaluate the success of their efforts over time.”[3]

About the Keewatin-Patricia District School Board

The KPDSB is one of the most geographically dispersed school boards in Ontario,[4] with 16 elementary schools and five secondary schools spread over 70,950 square km of land in northwestern Ontario.[5] The Board serves approximately 5,446 students,[6]  38% of whom self-identify as Aboriginal.[7]  Estimates are that this figure may reach 50% of the KPDSB’s entire student enrolment by 2010.[8]

Meeting the needs of this growing student population was one of the key factors that influenced the KPDSB to develop and approve the Voluntary and Confidential Self-Identification for First Nations, Métis and Inuit Students Policy (the Policy) in 2004.[9]  In 2005, KPDSB asked all of its Aboriginal[10] students to self-identify on school registration forms, making it one of the first school boards in Ontario to do so.

Why consider collecting student data?

Many factors led the KPDSB to consider collecting self-identification information from its Aboriginal student population, including:

  • A large and growing Aboriginal student population, particularly of First Nation heritage
  • Concerns about academic achievement gaps between Aboriginal and non-Aboriginal learners in the areas of literacy and numeracy, retention of students in school, graduation rates and advancement to post-secondary studies[11]
  • A lack of accurate, reliable data on the numbers and makeup of Aboriginal students, combined with an understanding that this data is a critical foundation for developing, implementing and evaluating programs that are designed to support Aboriginal students’ needs
  • A belief that a responsive, transparent and accountable policy can help students achieve their goals and enhance partnerships with Aboriginal parents and the general First Nation, Métis and Inuit community
  • A belief, strongly supported by senior leadership, that this was the right thing to do.

Goals of collecting student data

Collecting self-identification information from KPDSB’s Aboriginal student population shared and supported goals the Board had established for Aboriginal education within its jurisdiction, including:[12]

  • To reduce the academic achievement gap between Aboriginal and non-Aboriginal students
  • To provide high-quality learning opportunities that are responsive, flexible, and accessible to Aboriginal students
  • To request additional funding from the provincial government to support Aboriginal students in the same way that immigrant students are supported in southern Ontario
  • To improve EQAO (Education Quality & Accountability Office) test scores for Aboriginal students
  • To improve the retention rate of Aboriginal students
  • To improve programming to increase secondary school graduation rates
  • To promote effective, respectful working relationships and partnerships with Aboriginal parents and the general First Nation, Métis and Inuit community.

Challenges and planning

KPDSB faced a number of challenges when planning and promoting its Policy:

  • The need to secure the trust and support of Aboriginal families and their communities
  • Deciding who and how to consult Aboriginal families and communities
  • The need to counter historically ingrained fears of stereotyping and discrimination in the Aboriginal community, based on negative experiences with data collection in the past
  • The strong sensitivity to the information being collected, its use, confidentiality and privacy protection measures
  • The logistics of informing and surveying approximately 6,200 students dispersed over a large geographic area.

Preparing for the Policy and student survey

To address these challenges, the KPDSB took the following steps before sending Aboriginal families student registration forms seeking self-identification information:

  • Consulted widely with principals, teachers, students, communities, local groups and other key constituencies at least six years before drafting the Policy, to get feedback on the progress of Aboriginal student achievement and related program delivery
  • Reviewed literature, including Ontario Human Rights Commission publications and relevant legislation to prepare preliminary materials and a first draft of the Policy
  • Conducted extensive consultations on the draft Policy to make sure that Aboriginal families and communities understood and supported the initiative, and that they would self-identify on the school registration forms
  • Worked in partnership with KCDSB, NAEC through NOEL, local community groups and First Nation organizations to reach out to Aboriginal parents and community members
  • Designed an extensive communications strategy that included hosting local public meetings with Aboriginal parents, local newspaper coverage, letters to parents, communication to First Nation communities through their First Nation partners, and brochures handed out at centres within communities, such as malls
  • Developed Aboriginal parents and educators as advocates
  • Addressed privacy concerns by assuring that all data would be securely stored, protected by the Freedom of Information Act, treated in the same way as Ontario Student Records, not reveal individual data,[13] and would only be used to enhance Aboriginal education programming
  • Trained secretaries and front-line administrative staff in schools to sensitively and knowledgably answer parents’ questions about the registration form
  • Designed a simple survey question that asked students to self-identify as being of “Aboriginal ancestry,” which KPDSB clarified as including Métis and Inuit.

Administering the student survey    

  • On January 12, 2005, KPDSB mailed out student registration forms to over 6,200 students, accompanied by a cover letter and brochure explaining the Policy, why data was being collected, and how confidentiality would be protected
  • Parents could answer the survey question on behalf of the student, particularly for elementary school-aged children. They were given a few weeks to respond
  • KPDSB schools were responsible for tracking who had self-identified and who had not
  • KPDSB secretaries and front-line administrative staff followed up with every family who did not return the form, and asked whether they wished to answer the self-identification question
  • Families were advised to return the forms, even if the self-identification question was left blank
  • The student registration form was later revised to ask whether the student is of “Native Ancestry,” with the choice of selecting either “First Nation, Métis, or Inuit”
  • Revised forms were only sent to students who had self-identified in the student registration forms mailed out in 2005.

Some key student results

  • Out of an approximate sample size of 2,200 Aboriginal students, KPDSB estimates that just under 100% of elementary and approximately 80% of secondary Aboriginal students have self-identified on school registration forms[14]
  • Some key results from the self-identification data collected include:
    • There is an academic achievement gap between Aboriginal and non-Aboriginal students
    • With targeted support and programming, Aboriginal students appear to be improving at the same rate as non-Aboriginal students, showing that Aboriginal students are just as capable of achieving as non-Aboriginal students
    • There is an oral language gap between Aboriginal and non-Aboriginal students entering the system at the Junior Kindergarten and Senior Kindergarten levels, affecting Aboriginal students’ literacy skills
    • There appears to be a long-held belief about the ability of Aboriginal students to achieve that may be affecting the self-confidence of Aboriginal students and their communities.

Acting on the results

The KPDSB is committed to achieving the goals it had established for Aboriginal education and reporting its progress to Aboriginal communities and the broader public. The Board continues to collect and update self-identification data on an ongoing basis by asking for this information on student registration forms given to all new students. Secretaries and front-line administrative staff continue to be trained on how to discreetly and respectfully speak to students and their families about the Policy and address questions. Other steps the KPDSB is taking include:

  • Reporting its progress by using a variety of communication tools like public Board meetings, the KPDSB website, press releases and videoconferencing to reach remote communities
  • Placing special emphasis on celebrating the achievements and progress of Aboriginal students
    to encourage and inspire Aboriginal students, their communities and the broader public
  • Identifying and addressing barriers by developing targeted programs, policies and initiatives aimed at supporting Aboriginal students, families and communities, as well as KPDSB employees. Some examples include establishing the Policy in all KPDSB schools and committing to developing a brochure that highlights the successes of the Policy’s results for distribution to students, their families and communities
  • Implementing a Self-Identification Oral Language Project, sponsored by the MOE’s Literacy Numeracy Secretariat, to improve oral language skills which can lead to increased reading comprehension.[15]
    • All JK, SK, and Grade 1 teachers from KPDSB and its eight NOEL boards are involved. Teachers work directly with an international literacy expert to learn and effectively implement oral language strategies to help students develop their expressive language skills
    • Data is collected through the Oral Language Assessment (OLA), which is a measure of the students' receptive language, as well as establishing a text level for SK and Grade One students
    • The project results to date are showing that, with appropriate instruction, Aboriginal students are improving their OLA scores[16]
  • Implementing Character Development initiatives that are based on Anishinaabe Seven Grandfather Teachings. Supported by these teachings, KPDSB has been helping students through restorative practices, progressive discipline and Aboriginal healing circles. The results have been gains in creating a culture of caring and inclusion, and a greatly reduced number of formal suspensions[17]
  • Organizing Voice for Vision retreats, where all KPDSB secondary school students assemble in a retreat setting to identify concerns and ideas that make for successful learning. Information sessions are facilitated by Student Success Teachers. A summary of ideas is shared with each school and action plans are developed and implemented, with student input and participation.[18]

Best practices  

  • When engaging First Nation communities, it is recommended to ask their permission first, before discussing pertinent issues with regional Provincial Territorial Organizations and/or Tribal Councils such as Grand Council Treaty #3, as well as other Aboriginal organizations within the local community, such as the Métis Nation of Ontario
  • Create an effective communications plan, including print materials such as informational brochures that families can take home to read
  • Develop Aboriginal parents and educators as advocates to help explain the Policy and its implementation goals
  • Conduct extensive, transparent consultations
  • Listen to partners and be attentive to stakeholder concerns
  • Address privacy and confidentiality concerns, and assure that the data collected will be used in a positive way that is directly related to improving Aboriginal student achievement and reducing gaps
  • Train secretaries and other front-line staff about the Policy so that they understand the initiative, are sensitive to and can respond appropriately to the concerns raised
  • Report results to stakeholders and affected communities.

Lessons learned

  • “The collection of self-identification data confirmed that a gap does exist but also demonstrated that Aboriginal students are perfectly capable of achieving at the same level as non-Aboriginal students. This is an important fact to share with students, families, their communities, and the broader public.”[19]
  • “The collection of self-identification data helped KPDSB design and implement targeted programs and supports for Aboriginal students that would not necessarily have been thought of or considered.” [20]
  • “When you ask difficult questions, you may learn things about yourself that you are not comfortable with, but you must still respond appropriately.” [21]


[1] The Ontario Ministry of Education (the MOE) defines “Aboriginal” as including First Nation, Métis and Inuit peoples. According to MOE, “in keeping with the definition of Aboriginal peoples under the Constitution, all self-identification policies developed by school boards need to recognize and address the following four cohorts of Aboriginal students attending provincially funded schools in Ontario: one, First Nation students who live in First Nation communities but attend provincially funded elementary or secondary schools under tuition agreements; two, First Nation students who live in the jurisdictions of school boards and attend provincially funded elementary or secondary schools; three, Métis students who attend provincially funded elementary or secondary schools; and four, Inuit students who attend provincially funded elementary or secondary schools.” Aboriginal students who live in First Nation communities and attend federally funded elementary and secondary schools in First Nation communities would not be represented in the self-identification policies developed by provincial school boards. Ontario Ministry of Education, Building Bridges to Success for First Nation, Métis and Inuit Students (2007) at 9 online: www.edu.gov.on.ca at 9 [MOE Report]. According to the 2001 Census, more than 75% of the Aboriginal population in Ontario lives within the jurisdictions of provincially funded school boards. Ibid. at 7.
[2] Ibid. at 6-7.
[3] Ibid. at 8.
[4] Ontario Ministry of Education, Unlocking Potential for Learning:  Effective District-Wide Strategies to Raise Student Achievement In Literacy and Numeracy – Case Study Report Keewatin-Patricia District School Board (2006) at 13 online: www.edu.gov.on.ca.
[5] In a March 23, 2009 telephone interview with Commission staff, Larry Hope, KPDSB’s Director of Education, states that, “in terms of square kilometers, [KPDSB’s operating area] is geographically equivalent to the size of France” [KPDSB Telephone Interview].
[6] In 2008, the KPDSP had a full-time equivalent of 5,446 students enrolled. This number may have fluctuated since that time. See Keewatin-Patricia District School Board, 2008 Director’s Annual Report (2008) online: www.kpdsb.on.ca [Annual Report].
[7] The KPDSB adopts the definition of Aboriginal endorsed by MOE.
[8] Annual Report, supra note 6.
[9]Keewatin-Patricia District School Board, Board Policy 315 (2004) online: www.kpdsb.on.ca [Board Policy].
[10] Please note that the term “Aboriginal” will be used to refer to First Nation, Métis and Inuit students throughout the remainder of the document, unless specifically stated otherwise.
[11] MOE Report, supra note 1 at 6 and Board Policy, supra note 9 at 2.
[12] Board Policy, supra note 9 at 1-2.
[13] “Where numbers are small enough so that individual information may be revealed, no such information will be communicated. The number is set at 15 or less students.” Ibid. at 3.
[14] MOE Report, supra 1 at 19.
[15] Northern Ontario Education Leaders (NOEL), “Oral Language SIP/LNS Oral Language Project” online: NOEL www.noelonline.ca/index.php?pid=39 [NOEL Oral Language]. See also Annual Report, supra note 6.
[16] NOEL Oral Language, supra note 15.
[17] Annual Report, supra note 6.
[18] Ibid.
[19] KPDSB Telephone Interview, supra note 5.
[20] Ibid.
[21] Ibid.

 

University of Guelph

Founded in 1964, the University of Guelph (the U of G) includes seven colleges, with programs spanning the natural and physical sciences, social sciences and the humanities. The U of G, which is committed to equity, is ranked as one of Canada's top comprehensive universities because of its dedication to student learning and innovative research.[1]

In 1990, U of G administered a full-scale workforce census and set up an employment equity policy and plan, following work that started in 1987 when the University made a formal commitment to the Federal Contractors Program (the FCP).” [2]  Under the FCP, provincially regulated employers with more than 100 employees that want to earn federal government contracts of $200,000 or more must show a commitment to implementing employment equity.[3]

This means employers must work with employees to identify and remove systemic barriers to selecting, hiring, promoting and training four designated groups – Aboriginal Peoples, members of visible minorities, women and people with disabilities. Employers must also take steps to increase the participation of these groups at all levels of employment by, for example, collecting internal workforce information, or internal representation data, via a self-identification survey that meets the legal requirements of the Employment Equity Act and Regulations. Since then, U of G has conducted a full workforce census in 2000 and taken steps to promote equity and achieve a representative workforce.[4]

Goals of the workforce census

The key goals of the workforce census were to help U of G:

  • Get an accurate picture of the representation of the four designated employment equity groups in U of G’s workforce
  • See if its workforce reflected the Canadian labour market
  • Create an environment that attracts a diverse workforce and encourages all current and prospective employees to work to their full potential, without consideration of issues that are unconnected with the ability to perform
  • Adopt and implement, on an ongoing basis, employment equity strategies to identify and remove barriers to equity.

Challenges and planning

When planning how best to collect data in 2000, U of G faced several challenges, including:

  • Getting buy-in across the organization, including 11 union and employee groups
  • Countering negative perceptions about employment equity and individual abilities
  • Strong sensitivities around the information being asked, its use, handling and confidentiality
  • Responding to the exclusion of non-designated groups, and employee concerns that the focus was only on the four designated groups
  • Balancing limited resources with the need to reach several thousand employees (full-time and temporary), located on and off-campus,[5] and making sure that the highest number complete the survey in the time given.

Preparing for the workforce census

Before launching the workforce census, U of G, with guidance from the FCP Criteria and the Guidelines, took the following steps:

  • Organized an Employment Equity Committee (the EE Committee) that was consulted on all major decisions about the survey including the communications, lay-out, content and processes. The EE Committee was chaired by the Director of U of G’s Human Rights and Equity Office (HREO) and made up of senior management members of the University’s academic and administrative operations, representatives from union and employee groups, the Director of the University’s Communications and Public Affairs department, and members from past EE committees at Guelph.
  • Tasked the EE Committee with advising the external consultants hired to do the employment equity research activities on campus, which included the survey of the University’s workforce in 2000, an employment systems review to identify systemic barriers and the development of an employment equity plan.
  • Identified a one-week time period for “Census Week” during which the majority of employees were typically available.
  • Designed a comprehensive communication strategy, including community consultations, town hall meetings, information sessions, employee group meetings, a poster campaign, campus press articles, notices in paycheques, radio announcements and a toll-free telephone line to respond to questions.
  • Developed key messages to address the concerns of non-designated groups - on how everyone benefits from employment equity, the goal of identifying and removing barriers to employment, retention and promotion so that all employees are treated equitably, and that anti-discrimination steps would apply to all groups facing systemic discrimination.
  • Created survey packages for all on- and off-campus employees. The package included a survey form, a return envelope, a message from the HREO Director, information hand-outs like frequently asked questions, contact information, U of G’s Code of Confidentiality and a cover letter endorsed by U of G’s President and the presidents of all of the union and employee groups.
  • Addressed privacy concerns by stressing that no individuals would be identified, the information collected would remain confidential and separate from regular personnel records, and that the data collected would only be used for employment equity purposes.
  • Designed a voluntary survey that was short and easy to complete. Alternative accessible formats could be requested, including English and French options.
  • Developed special pin numbers for all employees so that there was some means of identifying them when they returned the survey. After the 2000 census, the option of completing the survey on-line was made available, requiring a Userid, password, and ID number.
  • Maintained strong leadership, support and collaboration among EE Committee members to guide the project to its completion.

Administering the workforce census

  • U of G’s “Census Week” took place March 6-10, 2000.
  • The census was on paper and included four questions. All employees who had worked there for three months or more were asked to voluntarily declare whether they were members of one or more of the four designated groups.
  • An external consulting company administered the census, collected, and analyzed the data off-site, and reported the overall results to U of G.
  • HREO staff and the consultants were available to answer questions or concerns.
  • Since then, U of G has collected, followed up and updated the survey data itself.

Some key results

  • In 2000, the return rate[6] was 74% and the response rate[7] was 70% for regular full-time employees.
  • U of G’s current return and response rates are 80% or higher, and a bit lower in the case of temporary employees.[8]
  • The external consultants analyzed and interpreted the data, and compared the results to external labour market availability data (Statistics Canada census data).[9]  
  • The key results from the data analysis showed that:
    • Members of the four designated groups were all under-represented in varying degrees among University employees in one or more federally defined employment equity occupational groups, on the main campus and at satellite campuses.[10]
  • After the 2000 census, the consultants did an employment systems review to help U of G identify and remove discriminatory barriers in its policies, procedures and practices. The workforce analysis helped inform this process, as did interviews and focus groups with a range of University constituents, including “lesbian, gay, bisexual, transgendered and transsexual” (LGBTT) persons.[11]
  • The employment systems review revealed many positive features of U of G’s work environment that supported employment equity goals.[12] However, the review also found inconsistencies, policies, practices and some elements of the workplace culture that negatively affected employees, particularly equity-seeking groups.[13]

Acting on workforce census results

  • A review of the workforce analysis and the employment systems review was shared with the EE Committee and circulated to the broader employee population through their representatives on the EE committee, employee newsletters, list-serves, meetings, university newspapers and the HREO website.
  • U of G used the consultants’ findings and the EE Committee recommendations to develop an employment equity plan for 2003-2007 (the EE Plan). This EE Plan included:
    • Senior leadership’s ongoing commitment to employment equity
    • Setting and communicating equity goals for hiring in underrepresented areas, as appropriate.
    • Tailoring outreach and mentoring programs for designated groups that are under-represented, and groups that are historically disadvantaged in employment.
    • Developing and delivering equity training for managers and supervisors. 
    • Continuing to offer staff human rights and equity training courses
    • Holding managers and senior managers formally accountable for meeting goals, monitoring and reporting on progress.
  • The workforce census results are stored in a database, which U of G regularly updates by providing surveys to employees who are new or who want to change previously submitted information.
  • Follow-up is done on a periodic basis to communicate with employees who did not return a form.
  • The entire survey package is currently available in an on-line format.
  • U of G’s new employment equity plan for 2008-2012 can be found on U of G’s website at www.uoguelph.ca

Best practices and lessons learned

  • Before starting to collect data, develop a framework that addresses such key questions as the purpose of collecting data, what data will be collected, about who, how, when, etc.
  • Get buy-in and feedback from key constituencies in the organization, and conduct community consultations well in advance of the survey launch.
  • Share ownership of the process with all stakeholders and work collaboratively to make sure the process is transparent
  • Address participants’ privacy protection and confidentiality concerns.
  • Develop a plan that contains realistic expectations and reflects the organization’s structure, resources, technology, culture, needs and circumstances.[14]
  • Design an appropriate survey instrument, consider what kind of data is to be gathered, and what your organization is prepared to do with the data once it is collected.[15]
  • Invest in a well-developed communications strategy.
  • Update data on a periodic basis and do follow-up.
  • Strive for high return/response rates to get the most accurate picture of the workforce and to meet the expectations for establishing a successful employment equity program.


[1] University of Guelph website, online: www.uoguelph.ca/. In 2008, U of G was ranked by Maclean's magazine as the fourth-best comprehensive university in Canada (“comprehensive" indicating institutions with significant research activity and a wide range of programs at the undergraduate and graduate levels, including professional degrees): See Maclean’s, “Comprehensive Rankings” (2008), online: Macleans.ca oncampus.macleans.ca
[2] University of Guelph, “Employment Equity Survey March 6 to 10” (1 March 2000), online: News@Guelph www.uoguelph.ca/atguelph/00-03-01/articles/equity.html.
[3] Human Resources and Skills Development Canada, Federal Contractors Program, online: www.hrsdc.gc.ca [FCP Program].
[4] See Human Resources and Skills Development Canada, Guidelines for the Employment Equity Act and Regulations: Guideline 4 Collection of Workforce Information, online: Human Resources and Skills Development Canada www.hrsdc.gc.ca [Guidelines].
[5] All full-time and temporary employees located on the U of G’s main campus were surveyed, as were employees not located in Guelph – those working at the University’s agricultural colleges (Alfred, Kemptville and Ridgetown campuses) and at the U of G’s research stations.
[6] The return rate is defined as the percentage of surveys returned either blank or completed. 
[7] The response rate is defined as the percentage of those who completed the survey.
[8] The FCP expectation is a return rate of 80% or greater.
[9] After 2000, the University’s Institutional Research and Planning office has assumed this responsibility.
[10] University of Guelph, Employment Equity Systems Review Summary Report, (2002) at 2, online: www.uoguelph.ca/hre/eep/docs/esrevieweng.pdf  [Systems Review Report]. For more details about the 2000 Workforce Census results see University of Guelph, Report of Employment Equity Workforce Analysis (2000), online: www.uoguelph.ca/hre/eep/docs/eewfa_eng.pdf [2000 Census Results].
[11]The employment systems review aimed to identify and remove barriers for “equity seeking groups” at the University who have historically been disadvantaged in employment. This included people who fell within the four designated groups and “lesbian, gay, bisexual, transgendered and transsexual persons.” Systems Review Report, supra note 10 at 1.
[12] For example, the University’s climate was “generally positive,” the senior administration was strongly committed to employment equity, and equity considerations had been incorporated into faculty hiring policies and procedures to make the process more streamlined and transparent. Ibid. at 2.
[13] Ibid. at 8.
[14] For U of G to get the support and high participation rate it needed, the EE Committee was aware that its organizational culture required a process that was highly consultative and transparent in nature to succeed.
[15] U of G decided to design a short four-question employment equity workforce survey that complied with the Guidelines and provided a sufficient level of data that it, as an organization, was prepared to address and act on. The University decided not to ask other questions, such as about sexual orientation, because there was no comparator data available from Statistics Canada at the time. In a March 10, 2009 telephone interview with Commission staff, Patrick Case added that, “we did not want to commit to collecting data and not have hard answers as to what we were going to do with this data.” The Guidelines for the Employment Equity Act and Regulations and FCP Criteria also do not require contractors to collect such data. See FCP Program, supra note 3 and Guidelines, supra note 4.