Welsh Revenue Authority equality report 2021

At the Welsh Revenue Authority (WRA), we’re responsible for collecting and managing 2 devolved Welsh taxes; Land Transaction Tax and Landfill Disposals Tax, on behalf of the Welsh Government. The revenue we raise funds public services, like the NHS and schools, in communities across Wales.

We’re committed to helping deliver a fair tax system for Wales through what we call ‘Our Approach’ - a Welsh way of doing tax. By working collaboratively with representatives, partner organisations, taxpayers and the public, we make sure taxes are collected efficiently and effectively.

We base everything we do on our Corporate Plan 2019 to 2022. This sets out our purpose, strategic objectives and longer-term ambitions. We report on our work annually - see our latest Annual Report and Accounts 2019 to 2020.

We’re a Civil Service organisation, the first non-ministerial department created by Welsh Government.

We’re a small and multi-skilled organisation of more than 70 people, with talents, skills and experience spanning 14 different professions. We champion innovation, collaboration and shared decision-making. And we empower and entrust our people with high levels of responsibility and autonomy.

Up until February 2020 we were mainly based in Treforest, but our offices were severely flooded and this was shortly followed by the national lockdown restrictions resulting from the impact of COVID-19. Therefore our people have mainly worked from home since February 2020.

Our people are highly engaged, ranking highly in the annual Civil Service People Survey every year since we were formed. You can find out more about what our people think about working for us by looking at our most recent People Survey results.

We’re proud to rank so highly across the Civil Service for Inclusion and Fair Treatment (in the top 10 of over 100 employers every year), with our people’s responses being particularly high to questions such as “I am treated fairly at work” and “I think the WRA respects individuals’ differences”.

For further information about the WRA, please visit gov.wales/wra

The WRA is committed to helping to deliver a fair tax system for Wales by introducing a new Welsh way of doing tax. By working collaboratively with representatives, partner organisations, taxpayers and the public, this partnership-led approach, which we have termed 'Our Approach', ensures that taxes are collected and managed efficiently and effectively.

Our Approach is made up of 3 Welsh terms: Cydweithio, Cadarnhau, Cywiro, and is inspired by Our Charter, which consists of 8 shared beliefs, values and responsibilities.

Cydweithio – This literally means “to work together” and carries a sense of working towards a common goal.

Cadarnhau – This suggests a solid, robust quality that can be relied on. This is about providing certainty, being accurate and reinforcing trust.

Cywiro – This literally means “returning to the truth” and is about the way we work with you to resolve errors or concerns.

As Civil Servants, we also abide by the core values of the Civil Service Code:

• honesty
• integrity
• impartiality
• objectivity 

You can find out more information about Our Approach, Our Charter and our Corporate Plan 2019 to 2022 on our website.

We published our first Strategic Equality Objectives (2019-2020) in April 2019. This was in agreement with the Equality and Human Rights Commission, as publishing an initial 1-year plan (as opposed to the usual 4-year plan) allowed us both to fall into step with the 4-yearly reporting pattern of other Welsh public bodies, but also allowed us to establish short-term objectives that suited a newly formed organisation.

In 2020, we began work with the Wales Public Body Equality Partnership and were pleased to be one of the founding organisations. This partnership was initiated in April 2019 by the WRA, Sports Wales and Natural Resources Wales and has since grown to include 10 public bodies in total.

The partnership consists of:

• Welsh Revenue Authority
• Sports Wales
• Natural Resources Wales
• Welsh Language Commissioner
• HEFCW (Higher Education Funding Council for Wales)
• Arts Council for Wales
• National Museum Wales
• HEIW (Health Education Improvement Wales)
• Velindre University NHS Trust
• Cardiff and Vale University Health Board

The partnership pooled resources into creating 5 joint strategic equality objectives and agreeing joint actions and measures for 2020 to 2024. These objectives would be worked on together throughout that period, and also influence organisation-specific objectives as appropriate to each body.

The partnership commissioned Diverse Cymru to conduct engagement and consultation on the partnership’s behalf. We held consultation events throughout Wales and had 43 respondents to our consultation document. The results of this were fed into our final objectives.

The partnership’s work and objectives were subject to an Equality Impact Assessment and followed the Future Generation Commissioner’s 5 Ways of Working.

You can find the final objectives, along with our WRA-specific goals, in our first 4-year Strategic Equality Plan and Objectives (2020 to 2024) which was published in April 2020.

Today (31 March 2021) we’re pleased to publish our Annual Equality Report 2021 (covering the period 1 April 2019 to 31 March 2020).

Our equality report has been overseen by our Tîm Arwain (Executive Team) and our Board.

Recruitment

As part of our recruitment process, we collect data on all 9 protected characteristics under the Equality Act 2010:

• age
• disability
• sex
• pregnancy and maternity
• marital status
• religion or belief
• race and ethnicity
• sexual orientation
• gender reassignment

Prospective candidates are asked to complete a self-declaration equality questionnaire when they apply for one of our jobs; only our HR team has access to this information.

Our HR team then anonymises the data and stores it securely by role the application relates to. We review this data at least twice a year to identify trends.

Our people

We collect data on 8 of the 9 protected characteristics for our people. We record 4 protected characteristics on an individual’s HR file:

• age
• sex
• pregnancy and maternity
• marital status

Only our HR team and those who support our system are able to access the above; we have measures in place to make sure that access is only granted with a significant business reason.

We ask our people to self-declare 4 other protected characteristics on their profile on our HR System:

• religion or belief
• disabled status
• race and ethnicity
• sexual orientation

We launched this self-declare option in October 2018. However, completion is not compulsory. We encourage our people to fill it out, explaining that if we have a strong set of data, it helps us create better people policies and understand how diverse we are as an organisation. We still have work to do to encourage more of our people to self-declare.

We do not currently record gender reassignment. We believe recording this information in such a small organisation could have a negative impact on individuals’ privacy and the data set would be too small to be analysed.

Our tax services

When delivering our tax services, we collect data on age of taxpayers paying Land Transaction Tax.

We collect this information because it helps us make sure the right amount of tax is paid by the right person. We’re not recording the information for equality purposes.

We have not carried out any analysis of these taxpayer data sets for equality purposes yet.

We’d intended to look at what further data we could gather to assist in assessing the impact of our tax services on protected groups during 2020, however the impact of the flooding on our offices, and COVID-19 has hampered progress in this area. It is something we intend to revisit in 2021 to 2022.

Complaints

When receiving complaints, we do not ask anyone to give us any diversity data. Our aim is to encourage as much feedback as possible to improve our services. We believe asking people to complete diversity declarations forms could create barriers to people giving us feedback. We’ll continue to review this approach.

If we receive a complaint about or referring to discrimination, or a negative impact on protected characteristics, it is recorded and sent to our Chief People & Communications Officer to review. We have not had any such complaints so far.

On 31 March 2020, we employed just over 70 people. Meaningfully interpreting diversity data is difficult in an organisation of our size, where just a small number of individuals can change organisation-wide percentages significantly. It also means we’re unable to publish most of our diversity data relating to the 9 protected characteristics.

As an organisation, we put great importance on protecting people’s privacy and their data, in full compliance with the Data Protection Act 2018. This applies to our people, our customers, stakeholders, and those that apply for jobs with us. We do not publish data which could reveal an individual’s or a small group of individuals’ identities, to protect their privacy. This means we will not publish data with groups fewer than 10 people. But where we can publish data, we will do so, and where we cannot, we will provide a narrative.

We collect data for both people who apply for jobs with us, and for those employed by us. We review our equality data at Tîm Arwain, WRA’s executive team, and at the WRA’s Board. We take what we can from this data to consider how well we’re doing and discuss areas for improvement.

We reviewed the diversity information held on applicants for our jobs and our current workforce as of 31 March 2020. What we can publish is contained below:

Men and women are represented at every level of the organisation, from our apprentices to our Board.

Men make up 43% of our organisation, and women 57%. During similar periods, this was:

• broadly in line with the Civil Service, at 46% male and 54% female
• significantly more gender balanced than the public sector, at 33% male and 67% female
• somewhat more female than the working population of Wales, at 53% male and 47% female

On 31 March 2020:

• 4 of the 7 members of Tîm Arwain (our Executive Committee) were women
• 3 out of 9 members of our Board were female
• proportion of men and women is fairly even across grades, but with more women represented at lower grades

The gender split of our grades is something we keep under review. If it becomes a longer-term trend, we’ll investigate further for possible reasons why this is, and what actions we can take.

Gender pay gap

Since 2017, employers with 250 or more employees have had to publish and report specific figures about their gender pay gap.

We are too small an employer to be required to publish our gender pay gap, but we do calculate it and present it annually to our Tîm Arwain for discussion and action.

Our calculations do show that our mean and median pay is significantly higher for men than for women. There are 3 reasons for this:

• a higher proportion of women in the grades below our median pay point (HEO and below)
• a lower proportion of women in the grades at our median pay point and above (SEO and above)
• less women at the higher ‘spine points’ in their pay scale than men

Our median pay sits within our SEO pay scale. When looking at staff by gender, at the grades below SEO, and SEO and above, the below table shows one main reason for our gender pay gap:

At our size, these numbers could change significantly with only a few starters or leavers, however they have been relatively consistent over the last 3 years. With staff turnover, current vacancies and new roles, we expect to recruit around 15 people over the next year. We will review the demographics of these vacancies, and their impact on our gender pay gap.

Our pay system is based on either 3 or 4 ‘spine points’ (depending on grade), with our people progressing up these spine points after each year of service until they reach the top spine point of the scale. We have seen significantly more women join us on promotion than men, and so more women are in the lower spine points of their pay scale.

Having reviewed this pattern since 2018, we implemented a new pay on promotion policy in 2020, to more equally treat our staff who had been in a role on temporary promotion prior to being made permanent. This has had a positive impact on our gender pay gap, and along with other changes, our projections show our gender pay gap lessening even further into 2022 to 23, potentially reducing as much as a third.

The WRA is a small organisation, but with 14 teams representing as many different professions. Some of those professions are dominated by one gender in the UK workforce, such as in Digital, Data and Technology (male-dominated), or Human Resources (female-dominated). We plan to do further analysis over the next year as to whether the professional demographics of the WRA are having an impact on our gender representation across the organisation, and by grade in particular.

We had begun work with Chwarae Teg to become a FairWork Employer in 2020, but unfortunately could not progress this as we turned our priorities and capacity to supporting our people and our customers during the pandemic. We hope to restart this work in the next few years.

Our pay scales are published on our website.

Employees by working pattern and contract type

Our employees by working pattern and gender is too small a data set to publish, but is equally split by gender.

We encourage a culture where people can work flexibly and value the impact of role modelling, with both male and female members of our Tîm Arwain openly working to flexible working patterns. We:

• have an open process for applying to work flexibly and we encourage line managers to talk to staff about the opportunities for alternative working arrangements 
• provide the technology so that all our people can work outside of the office, at home, in another office, and on the move to help them maintain a work life balance - both before and after this current period of home working
• are proud to display the Happy to Talk Flexible Working on our website
• advertise all jobs, unless there is a specific business reason, as open for part-time, job share, or flexible workers.

The WRA employs only a very small number of people on temporary contracts or as agency workers, and so is too small a data set to publish. The headcount of temporary and agency workers across the year are published in our Annual Report and Accounts.

Employees by age

Compared to the wider Civil Service, the WRA has a significantly younger workforce:

These proportions broadly reflect the age bandings of people who apply for jobs at WRA.

Job applicants

In 2019-20, we received 198 job applications, conducted 41 interviews and appointed 11 new members of staff. We cannot publish any further breakdown of this data, but some insights we have gained were:

• gender: men were more likely to apply for roles, but women are more likely to be offered a role
• age: younger people (aged 16 to 34) were more likely to apply for roles and then be offered a role (aged 16 to 50)
• ethnicity: applications, interviews and jobs offered to people declaring themselves as from Black, Asian or Minoritised Ethnic communities were higher than Wales’ average demographics
• disability: people applying for roles with us and who declared a disability was much lower than the average for Wales, this reduced slightly through the recruitment stages and increases once staff are employed and self-declare, suggesting more applicants did not feel comfortable sharing this information, rather than people with a disability not applying for our roles
• marriage and civil partnership, sexuality, religion or belief: there was little variation between recruitment stages and little change to note when compared to the general population
• gender reassignment, pregnancy/maternity: these figures were too small to share or provide a narrative
• people who have ticked “prefer not to say” for their protected characteristics: very few individuals chose this option during recruitment, which is positive as it suggests that people trust us to hold and act appropriately with their data

Our Board

Our Board is made up of a Chair, the Chief Executive, 5 Non-Executive Directors, 2 Executive Directors and a Staff Elected Member, who is an employee appointed to the Board through a staff ballot. The Staff Elected Member is a full member of the Board in their own right, sharing their individual experience and views, and can be of any grade. We currently have a vacancy for one Non-Executive Director.

Our Board currently has 9 members, meaning that most diversity data cannot be published. One area we think is appropriate to share is the gender breakdown of our Board (as of 31 March 2020):

• 3 were female (5 at time of publication)
• 6 were male (4 at time of publication)

On age, we have a positive age distribution on our Board.

Training

We record on our internal HR System how many people have completed training and are able to compare that to their diversity characteristics. At the time of writing, this is not an area for concern. But this is something we’ll continue to monitor.

We still have more work to do in encouraging people to record their training and also their diversity statistics to make this data more useful for our learning and development planning. This may also increase numbers to publishable levels.

Non-publishable data

There are some data sets which are too small to currently publish and to provide a narrative on.

This data is monitored internally by our HR team and is regularly reviewed. So far there hasn’t been any cause for concern; but we will provide a narrative when we are able.

The relevant data is:

• men and women by job held
• people that have left the organisation
• people that moved internally or applied to do so
• people involved in grievances
• people involved in disciplinaries

Equality Impact Assessments

During the period of this report (2019-20) we created bespoke WRA templates for Equality Impact Assessments (EqIAs) and produced guidance for our staff, engaging with partners and experts to assist us in building our capability in this area.

We provided training for our people in order to embed the EqIA process across the organisation, with a focus on the areas most likely to have an impact – policy, budgeting and change. A working group of senior functional leaders was set up to support the roll out of the approach.

We have also changed the templates for papers which are presented to our Board and Tîm Arwain, adding a mandatory section asking whether an EqIA is required, and to provide a summary of any potential impacts. This has ensured that equality is duly considered in strategic decision making, and, more importantly, is more often discussed and is becoming part of our ways of working.

Going into 2020-21, we are more confident and capable completing EqIAs, and look forward to further building on the progress we have made. During 2020-21, using the new process, we have undertaken EqIAs as we have rolled out new strategies, such as our Welsh Language strategy, as well as new policies, such as our tax dispute policy.

Equalities and the EqIA process continues to be a top priority for the WRA. We are continuing to support our people with training and raising awareness of key issues and areas of learning. We will provide further information on the progress we have been making in our next Equality Report.

Objective 1: increase understanding of equality across our organisation

All staff have completed equality training as part of their induction and we require staff to re-train annually if they are taking part in recruiting new people. For example

• Equality Impact Assessment training
• Unconscious bias training mandatory for all recruitment panel members
• running Mental Health Awareness training for line managers

We provided key staff with training on EqIAs from Diverse Cymru and have created templates and guidance.

We discuss equality and diversity at our People Committee, Tîm Arwain and Board. Papers presented at these meetings must include a section on equality impacts and considerations.

While we follow the Social Model of Disability, we acknowledge that we have more work to do in promoting it and fully embedding it.

Objective 2: better understand the diversity of our customers and our employees

We continue to use publicly available data to understand the diversity of our customers. We use publicly available data and feedback from customers to assess the impacts of our policies and processes on our customers.

Whilst we already capture a lot of data about taxpayers for the purposes of calculating and processing the tax returns and payments, none of this data is collected for the purposes of establishing the diversity of our customers. We’re not able to collect diversity data via the tax return. Currently only age-related data is captured on tax returns, which could then be capable of providing us with such an analysis.

As a relatively new organisation, we are continually learning about our customers, both through data analysis, but also user research and engagement, and from this how we can improve our services to meet their different needs. Understanding our customer’s needs is and will continue to be an important part of our approach. In terms of collecting our own diversity data about our customers in future, this is something we’ll keep under review, and look for appropriate opportunities to do this.

We’ve continued to develop an understanding of the diversity of our people, which has been outlined above. We still have more work to do in encouraging people to record their diversity statistics to make the data more useful and potentially increase numbers to publishable levels.

Objective 3: increase the accessibility of our published information and end-to-end services, including our tax system

We’ve made positive progress against this objective.

We completed an accessibility review of our online services – our website, our tax system and both our online and paper forms. From this we developed an action plan to make several improvements to our tax system to make it more accessible – we published this as part of our Accessibility Statement in September 2020. Using our internal digital specialist capabilities that we have started to build in 2019-20, we implemented many of these changes during 2020-21.

We also used the findings from our review to make improvements to the accessibility of our website, for example, through accessible PDFs and subtitling our videos. We’ve ensured that our new content is accessible and readable and have developed a plan to improve our existing content.

We’ve continued to raise awareness of accessibility and assisted digital support, and developed an enhanced support policy so our people able to help taxpayers who may need extra help.

Finally, we developed a consistent approach to responding to requests for assistance using digital services and provided additional training to our people.

Objective 4: increase the accessibility of our external events

We are conscious about equality when hosting external events and only book accessible venues. We’ve drafted standards and guidance for making our events more accessible. Since 2019-20 we’ve also been exploring ways to deliver some of our event material in more accessible formats, for example using webinars that can be accessed online and providing captions to support customers with hearing loss or deafness.

Objective 5: be considered a fair employer by our people and applicants for our jobs

We remained at the top of the top quartile for ‘Inclusion and fair Treatment’ in the Civil Service People Survey, ranking fourth out of over 100 organisations.

During 2020-21 we were awarded Level 2 Disability Confident Status, backdated to 2018. We only had to take one action to meet the standards, which was to encourage our suppliers and partners to be a Disability Confident employer, which we’ve now included within our standard contracts, stating our commitment and encouraging them to consider it as well. Having only one action outstanding reflected the positive progress we had made in this area over the last 2 years. Some of examples of the actions we had already taken in the period up to March 2020 included:

• offering a Guaranteed Interview Scheme, whereby applicants with disabilities who meet the role’s minimum requirements are guaranteed an interview
• offering all new roles as flexible working/part-time/job share by default
• offering and making available to disabled people apprenticeships, internships, and graduate placements, and only offering paid internships to increase participation
• accepting job applications in alternative formats
• running Mental Health Awareness training for line managers
• obtaining and using our Occupational Health provider to support both new starters and our current people, along with an Employee Assistance Programme (EAP) website and phoneline
• promoting the ability to join the Welsh Government’s staff group for disabled people during induction and on our intranet
• DSE assessment undertaken and specialist equipment and adjustments put in place promptly
• providing opportunities for coaching, mentoring, reverse mentoring
• having valued, permanently employed disabled colleagues

We plan to work towards gaining Level 3 status in 2021-22.

During 2019 to 2020 we began work on reviewing job adverts and recruitment processes, which resulted in re-wording and designing our key recruitment documentation and web pages in 2020 to 2021. There is more work for us to do in this area. We will build on the findings from our work on the accessibility of our internet and services to customers. And we will involve our relevant staff networks to focus on the experience of disabled people in our recruitment process.

We plan to look further into adopting the Civil Service Workplace Adjustment and Carers Passport scheme but have not done so yet.

Objective 6: remove barriers to joining and thriving in the workforce by encouraging flexible working

Flexible working is considered part of our culture and is valued by our staff, with the majority of staff working flexibly. We use the Happy to Talk Flexible Working logo on our job applications and on our website, and we discuss with hiring managers the possibilities for part-time, job-share, or flexible working arrangements with each role we advertise.

We advertise all our jobs, unless there is a specific business reason not to, as available as part-time, flexible working, or as a job-share. We have changed the wording on our job adverts to more clearly state that we welcome – not just consider – requests to work flexibly, and hope this will have a positive impact.

We are reviewing our guidance on processes for those returning to the workforce to provide the best experience we can, especially around parental leave. This will be something we will explore further in 2021.

As a result of the tragic flooding of the local communities around Nantgarw where our main office was located, many of our staff moved to home working in February 2020. This continued following the lockdown restrictions as a result of COVID-19. As a cloud-based organisation, we were able to move to home working with relative ease, supporting our people with the necessary equipment, such as chairs and desks to ensure healthy work practices. We have taken advantage of advances in technology, particularly the use of Microsoft Teams to keep in touch with each other and lessen feelings of isolation.

These experiences give us the opportunity to think differently about ways of working in the future when we can return to an office. We have all individually increased our skills in home working, and it has helped to remove unhelpful stereotypes about needing to be present in the office. We’ve been able to advertise more of our roles as home-working as a result of what we have learnt.

Objective 7: identify and remove bias and unfairness from our pay system

In spring 2020 we were proud to become an accredited employer with the Living Wage Foundation.

We monitor and regularly review our gender pay gap as well as look for signs of other pay gaps. In 2020, we introduced a change to our pay on promotion rules, as we noticed a trend that negatively impacted women. We have committed at Tîm Arwain into monitoring our gender pay gap closely and to doing further analysis to lessen the gap further.