Introducing Ofcom's new EDI assessment tool

Our new qualitative data collection tool has been designed in collaboration with Radius Networks, who we commissioned to develop a new approach to collecting qualitative workforce data.

The model has several aims:

to drive and monitor improvements to workforce diversity and inclusion;
to understand the changing priorities of the broadcasting sector; and
to support learning, evaluation, and collaboration within the sector.

Summary of how the new model works

The new tool takes the form of a maturity model, which assesses a broadcaster’s effectiveness at achieving a particular EDI objective across a series of levels. The model enables broadcasters to understand the degree of maturity in their approach to EDI and provides them with suggestions to help further develop their approach.

Questions are grouped by themes, which map across to Ofcom’s EDI guidance.

Broadcasters will be asked questions within each theme to assess whether they are ‘starting’, ‘committed’, ‘achieving’ or ‘excelling’ in each area.

Once a broadcaster has answered a question, they will be provided with suggestions on how they might progress their arrangements. Broadcasters will be provided with an assessment of how they are performing within each area, as well as an assessment and score based on how they are performing overall. This allows them to identify areas which require more focus.

All the questions and themes in the model can be viewed in the link below.

If a broadcaster would like to provide further data on any of their work or to qualify any of their answers, they are welcome to submit this information.

Implementation of the model

The model will be sent to broadcasters for completion alongside the annual quantitative workforce diversity data collection survey. It will replace the previous qualitative questions. As some questions in this model will help Ofcom assess compliance with their licence conditions it will be sent to all broadcasters with more than 20 employees who are licenced to broadcast for more than 31 days per year.

Questions that relate to licence conditions will be mandatory to answer; the other questions in the model are voluntary. If a broadcast chooses not to answer the voluntary questions, the model will count the response as if the broadcaster is at the lowest level of development in that area. This will affect the broadcaster’s overall score from the model. While we do not intend to publish detailed scores, Ofcom will report on completion levels.

The model will be provided as an online tool that will be sent out to broadcasters in April 2023. We will treat the first year of data submissions using this tool as a ‘beta’ phase, meaning we will be open to feedback from users to help us to refine the model, if necessary, for the following year.

Ofcom will use the information collected to identify trends across the industry, and to inform how we prioritise our future work. We will publish these trends, as well as other key insights, annually.

We do not intend to publish a table of scores, but we may report which category of maturity broadcasters are within for some questions or themes. If we find specific broadcasters are excelling, we may highlight their work and suggest they collaborate across industry to share their ideas or best practices. Equally, if we are concerned that specific broadcasters are failing to meet our expectations, we will contact them about how they can improve their approach to promoting EDI.

Broadcasters’ answers to the mandatory questions will not be the only way in which we assess compliance to their licence conditions, but it will give us a good initial indicator of whether we may need to take further action to evaluate whether a broadcaster is doing enough to meet its licence obligations to promote equality of opportunity.

We will also make the model openly available for use online so organisations from across the creative industries and beyond can use it to measure their own EDI arrangements. We hope the content and question asked in this tool will provide inspiration for collaborative conversations across the industry and other sectors.

Radius Networks is a consultancy specialising in EDI, they have supported over 600 international organisations build their EDI strategies and tools. They have previously built maturity models, including their ‘Network Maturity Guide and Reporting’ model that enables employee network leads and EDI teams to track and assess their development and progress throughout the year, providing benchmarks and suggesting outputs and recommendations for increased network impact.

We asked Radius Networks to investigate the suitability of similar maturity assessments (including Radius Networks’ own Network Maturity Guide) for us. They found that these models were good for providing a consistent and data-driven tool for self-assessment and for providing practical tips on how broadcasters could progress their maturity.

Together we developed themes to group the assessment questions into: ‘leadership and strategy’; ‘data monitoring’; ‘recruitment’; ‘retention, development and progression’; ‘culture and voice’, ‘commissioning’; and ‘freelancers’. These represent the core policy areas in Ofcom’s EDI guidance. They are also the pillars around which Radius Networks consider a successful EDI framework for broadcasters should be built.

Radius Networks developed questions aligned with specific requirements and recommendations detailed in Ofcom’s EDI Guidance for each theme in the model, using their own EDI expertise, desk research and input from Ofcom, experts and stakeholders across the broadcasting industry. The questions have been developed to help broadcasters understand the maturity of their EDI arrangements, to help Ofcom assess and track the progress of the industry and, where applicable, help assess broadcasters’ compliance with their licence conditions. Questions that aim to help Ofcom assess compliance will be mandatory.

Radius Networks then conducted user testing with EDI practitioners in broadcasting, looking at the concept, introductory messaging, categories, questions, and recommendations on how broadcasters

Strategy and leadership

Do you have a regularly updated equity, diversity and inclusion (EDI) policy statement or strategy, with specific arrangements relating to disability, race and sex, and ‘S.M.A.R.T’ objectives relating to workforce diversity and inclusion?
Do you have EDI governance structures?
Do senior leaders have EDI objectives?
Do you clearly communicate your EDI strategy to employees and other stakeholders?
Do you have senior EDI champions or sponsors or another mechanism to provide visible leadership on EDI?

Data collection, monitoring and evaluation

Do you monitor the diversity of your workforce, including those in senior roles, to identify any underrepresentation by disability, race and sex?
Do you monitor the diversity of your workforce, including those in senior roles, to identify any underrepresentation by other characteristics, such as age, religion/belief, sexual orientation, socio-economic background or geographic location?
Are you able to clearly identify where there is underrepresentation in your senior team when compared with a relevant benchmark, e.g., data for the UK as a whole or for the city/cities or region(s) within which you are based, and what your arrangements are for addressing this underrepresentation?
Have you undertaken communications or any other initiative to increase the completeness of the workforce diversity data collected by your organisation?
Do senior leaders regularly review 'live', recently collected data and workforce trends and take demonstrable action to drive equity, diversity and inclusion?
Do senior leaders and managers review trends in diversity data for absence, disciplinary, grievance and allegations of harassment, bullying and discrimination?
Do EDI monitoring and evaluation feed into revised EDI arrangements?

Recruitment

Do you promote your approach to EDI in your recruitment?
When recruiting do you take into account a wide range of indicators of background, experience or identity, such as socio-economic status and geographical background to help identify underrepresentation in all its forms?
Do you regularly review your recruitment process to ensure that it is fair and inclusive, drawing on current best practice?
Do you provide training on inclusive hiring practice?
Do you conduct onboarding or new starter surveys?
If the diversity of your workforce overall is not replicated at senior levels, are you taking evidence-based action in your recruitment policy approach to address this?

Retention, development and progression

Do you undertake any specific career development initiatives for underrepresented groups, such as leadership programmes, mentoring or sponsorship schemes?
Do you have any arrangements to address underrepresentation of a particular group in relation to succession planning and internal recruitment, particularly to senior roles?
Do you ensure that employees from underrepresented groups have equal opportunity to access learning and development opportunities?
Do line managers proactively encourage take-up of opportunities for learning and development?
Do you set targets relating to retention and/or progression?
Do you have a workplace adjustments policy and/or procedure?
Do you have a flexible working policy and/or procedure?
Do you conduct an anonymised exit process for all leavers?
Do you have a health and wellbeing at work policy and/or procedure?

Culture and voice

Do you regularly undertake surveys to assess the experiences of diverse and under-represented employees?
Do you take action based on the views and experiences of employees, particularly where colleagues from underrepresented groups appear to have different views and experiences?
Are there opportunities for diverse voices, including those from underrepresented groups, to feed into EDI strategy, planning and evaluation, for example through employee networks or a staff forum?
Do you provide resourcing to support any employee networks?
Do your employees have effective channels to raise concerns about your broadcast output?
Do you provide training on EDI to all employees?
Do you have a document that defines expected workplace behaviours?
Do you have a policy and process to address bullying, harassment and victimisation?

Commissioning

Do you have a diversity policy for content commissioning covering areas such as diverse on-air/screen representation or diversity of subject matter likely to appeal to a wide range of audiences?
Do you have a diversity commissioning policy designed to increase EDI in production teams. For example, do you specify anything about underrepresented groups in your contracts with production partners or monitor the diversity of content teams (e.g., through Diamond for the TV industry)?
Do you ringfence funding for diverse commissioning for on screen/air content and talent and/or production partners or content makers? Please let us know any EDI criteria production partners need to meet to receive ringfenced funding.

Freelancers

Do you have any policy and/or take any action to promote EDI among freelancers, either those who contract with you directly or with your production partners? Please use the upload facility at the end of this section to tell us about any specific examples you would like to share.
Do you place any EDI requirements on production partners in relation to freelancers contracted to work on your commissions?
Do you have a complaints procedure for freelancers working on your productions to report harassment, bullying, discrimination or victimisation?