Equality survey and data protection 

A common way of charting how well equality is realised at a workplace, for example, is to conduct an equality survey among the personnel or service users. 

A survey aimed at personnel can be used to find out, for example: 

• whether employees feel that their workplace is equal, 
• whether employees have experiences of discrimination, 
• whether employees have noticed discrimination against others, and 
• how effective employees consider the organisation's equality work to be. 

Data protection 

An equality survey may include sensitive questions. These can be, for example, questions about experiences of discrimination or questions related to special categories of personal data defined in the data protection legislation. However, receiving answers to such questions is important, as certain issues related to the realisation of equality can only become visible if people are asked directly about them.  An equality survey provides reliable information only if the respondents can

be sure that the information they provide will be treated confidentially. Providing the respondents with a comprehensive account of the manner in which their data will be processed creates trust and ensures the reliability of the answers received. If, on the other hand, the respondents fear that they may be identified based on the information they provide and too many persons handle the responses, they may be afraid to openly share their experiences. 

From the perspective of data protection, an equality survey may be carried out in two ways: 

• ensuring that no one can be identified from the responses or their combinations when formulating the questions, or 
• ensuring that the survey is conducted in compliance with the data protection legislation. 

If you end up collecting identifiable data, make sure that the data is rendered down to a general level before the results of the survey are processed by the planning team and, most importantly, before the results are published.  

People who know each other may recognize situations others have encountered or even identify a specific person based on their style of writing. For example, using open text fields may lead to a situation where identifiable data related to individuals is being collected in the survey. If open text fields are used, it is a good idea to contact the organisation’s data protection officer already when planning the survey and ask for advice on how to make sure that the survey will meet the data protection requirements.  

In addition to the survey questions, identifiable data may be received if, for example, personal links to the survey are provided or if the survey tool uses cookies or other analytics or monitoring tools. Therefore, it is advisable to inform the respondents whether cookies or other analytics or monitoring tools are being used in connection with the survey. 

When performing an equality assessment, remember that: 

• If possible, equality surveys should be conducted anonymously so that the responses cannot be linked to specific individuals. 
• If the data collected using different methods enables the identification of individuals, this is considered processing of personal data and the data protection legislation must be applied.