DE&I efforts are incomplete without a thorough internal review, one expert says

The first question Aubrey Blanche, CultureAmp’s senior director of equitable design, product, and people, has for leaders who say they’re committed to diversity, equity, and inclusion, yet don’t audit their performance review process is, “How dare you?”

“You’re not actually doing DE&I if you’re not auditing that, because so much of someone’s opportunity and experience hangs on that one process,” Blanche told HR Brew.

According to CultureAmp’s 2022 Workplace DEI Report, while 89% of companies globally have conducted a pay-equity analysis at least once, and 55% of companies conduct such studies annually, only 43% of companies have ever audited their performance review processes. Blanche conceded the analyses are not a “flashy thing to do,” but said, “As leaders, you have both a legal and an ethical obligation to protect people from harm and from discrimination. And you cannot stand up and say that you are doing that if you have not looked under the hood.”

There’s also a sound business case, according to Blanche, for auditing additional metrics beyond pay. A 2019 Advances in Economics, Business, and Management Research journal article found that perceptions of promotion injustice led to increased turnover intention among employees.

“We know that people who are engaged in [work]...are highly valuable to the business, and we know that human beings are exquisitely sensitive to being treated fairly and equitably. And so even if all you care about is driving workforce performance, [understand] that this is a crucial driver of that,” Blanche said.

Blanche walked HR Brew through how CultureAmp puts this philosophy into practice internally, applying data analysis to audit a broad array of employment decisions across the company for statistical inequity against underrepresented employee groups.

Roll up your sleeves. Blanche said the choice to expand equity audits came from a “strategic and a structural perspective.” The employee experience, performance, and development management platform started by auditing performance reviews for their 700+ employees: a process Blanche knew could drive pay discrepancies because companies often claim to pay for performance.

Then the company began analyzing promotions to ensure CultureAmp didn’t observe problematic patterns; for example, “performance ratings might be fair, but they’re not translating into that growth equitably for different groups,” Blanche said.

Typically, equity audits are discussed as differences in outcomes for employees by sex or race, but Blanche said CultureAmp also uses employee-provided HRIS data to look at differences by “disability, caregivers status, LGBTQ status, and native English-speaker status.”

The team creates statistical models to identify where pay, performance review, and promotion decisions may have statistical bias. Using performance as an example, Blanche said the models assess, ”On average, are people of color being rated ‘under performing’ at a higher rate than their white colleagues?,” among other questions.

The team doesn’t analyze the data just once. According to Blanche, they perform a pre-calibration audit which involves an initial data run and then discussions between managers and HR to make any necessary changes to employee pay, performance scores, or promotion decisions to address statistical inequities. Next, the team re-runs the models post-calibration meetings to ensure they’ve addressed all statistically significant inequity issues.

The process could go on for a while.

“If there are still issues in that second audit, we will recalibrate until we no longer identify statistical inequity issues. So we have a zero-tolerance policy for that,” Blanche explained.

Privacy please. None of this is possible without employee buy-in. CultureAmp relies on voluntary self-reported data.

Blanche said that most employees do disclose: Non-response rates range from 5% for a field like sex up to about 20% for “less traditionally collected” fields, like disability status. Even at the high end of the range, Blanche characterized the non-response rate as not that bad, noting they still have “enough data to pull meaningful insights.”

To encourage disclosure, Blanche said that only about 15 CultureAmp employees have access to employees’ demographic data and the company explains why they are “collecting [data], what [they] use it for, and who has access to it.”

After each pay, promotion, and performance cycle, employees receive an internal confidential audit report.

“All employees are provided a version of that report that allows them to cut by identity demographics, so that employees can see that our leadership team is using that data to specifically look at the quality of their experience and invest where it’s not working,” Blanche explained.

When asked to provide HR Brew with internal audit reports for review, Blanche said that CultureAmp is "unable" to share them due to confidentiality.

Start small. Blanche knows this process is a lot to chew on. Companies without the resources to do such an involved process shouldn’t, in her opinion, be afraid to start early in order to “build the muscle.”

“Let’s say you’re a company of 50 [employees], that doesn’t mean you need to do advanced statistics. Make a little pivot chart in Excel, and if the data looks severely different, take action,” Blanche recommended. “Small [sample sizes] shouldn’t be a barrier to you building some kind of review process, and you can strengthen and evolve that process as your organization grows and changes.”—SV

Do you work in HR or have information about your HR department we should know? Email [email protected] or DM @SusannaVogel1 on Twitter. For completely confidential conversations, ask Susanna for her number on Signal.