Pay transparency in the age of GDPR

Hello - i would like to implement full pay transparency at my organisation.
We believe that pay transparency will help to build trust and equity in the business as well as help us to uncover and rectify pay imbalances. Our plan would be to publish internally not externally.

We have reviewed salary levels, identified a few cases for adjustment and created groupings where levels of responsibility and KPIs are similar.

We offer an annual inflationary increase but we do not offer pay progression for performance or length of service so there are no ranges of pay at each level. Everyone who role has been graded at a specific level is paid exactly the same.

GDPR rules means it is illegal for us to publish this information because it would mean individuals pay could be identifiable.

So here are our options I think

  1. We show ranges of pay / make larger groupings of staff so that individual roles are not identifiable. This kind of defeats the point.
  2. We take a vote. If all staff agree to participating in pay transparency the exact pay for each level (not each role) will be published.

what have i missed? Has anyone found a better solution?

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Would it be possible to do 2. but include a gross pay transparency clause in contracts going forward? Genuine question as you’ve made me curious about this now. We just have a Salary Band Framework which is fixed to role titles. You can’t work out exact pay of everyone but there’s not much wiggle room so I don’t think people mind.