Promoting equality, diversity and inclusion

We are committed to supporting and promoting equality, diversity and inclusion.

We have an overarching EDI action plan running in tandem with our three-year Strategic Plan 2023-26.

We have set two equality objectives to progress our continued journey to drive forward EDI.

Objective 1: Develop our EDI leadership

As an independent body overseeing regulation and registration and setting standards for organisations, we recognise we have an important role in championing EDI practice and outcomes. This is why our first equality objective is focused on developing our EDI leadership. We understand that developing our EDI leadership includes promoting EDI in our work and those we oversee. It also includes using our influence and convening powers to be timely, visible and current in responding to emerging and ‘new’ EDI issues, whist maintaining the profile of more longstanding and persistent EDI matters.

Our Strategic Plan sets out our aim to make regulation and registration better and fairer. In doing so it sets out our intention that by 2026 EDI indicators across the regulators and Accredited Registers show significant progress when compared to 2022/23.

Objective 2: Build an inclusive workplace

We recognise that creating and sustaining inclusive workplace practices requires continuous commitment and action. This is why our second equality objective focuses on driving forward EDI within the workplace and more specifically building and improving upon our existing inclusive practices.

PSA first self-assessment on equality, diversity and inclusion and reflections on progress made

We have published our first self-assessment on equality, diversity and inclusion (EDI). The purpose of the self-assessment was to evaluate where and how we can improve EDI outcomes in our own processes and in those we oversee.

To provide us with a structured and objective approach, we used the EDI Standard of Good Regulation. Our self-assessment was carried out between February and May 2024 and used a modified version of the Performance Review Standard 3 to make it more relevant to our work and functions. It reviewed our EDI performance from 1 April 2023 to 31 March 2024.

We committed to assess ourselves robustly and objectively as part of our EDI action plan for 2023-24. Our intention was to demonstrate leadership by holding ourselves to account for the quality of our work on EDI. We also wanted to identify areas for improvement that would be taken forward in our EDI action plan for 2024-25.

Reflecting on progress made on EDI

The PSA Strategic Plan 2019-22 referred to the importance of: regulation protecting the most vulnerable; having a diverse staff team; and further improving organisational culture and upholding the values of the organisation (respect, fairness, integrity, transparency and teamwork). We also introduced our first EDI Standard of Good Regulation in 2019.

In September 2020, we set up our EDI Working Group – a staff-led group to support and promote EDI across the organisation and in those we oversee. In November 2020, we commissioned an independent EDI review that was completed in April 2021. The review findings pointed towards many positive aspects of our work that supported and demonstrated our commitment to EDI. It also identified areas to work on in terms of strengthening the leadership of EDI; the analysis of EDI issues internally and externally; and a review of our people plans and HR practices. It specifically recommended establishing an EDI action plan. We published our first EDI action plan in spring 2022. We have now completed our 2022/23 and 2023/24 EDI action plans.

In our 2023-26 Strategic Plan, we have a strategic aim ‘to make regulation better and fairer’, which includes an objective ‘to promote and monitor equality, diversity and inclusion in our work and in those we oversee’. Over the past five years we have had a strong focus on EDI, our values, and creating a positive internal culture. In our most recent staff survey (November 2023), 92% of staff agreed with the statement, “I am treated fairly” and 97% agreed with the statement, “I am treated with respect”. We also had very positive responses to an additional survey on psychological safety in March 2024.

Our findings from the self-assessment

There have been many changes since our first EDI action plan was developed and we recognised these as we reviewed our performance over 2023-2024.

Most notably, we have enhanced our expectations in relation to EDI for those we oversee. A new EDI standard designed to strengthen our approach to EDI within our accreditation programme was introduced to the Standards for Accredited Registers in May 2023. We also amended the requirements for meeting our EDI Standard of Good Regulation, making them more comprehensive, at the same time.

In addition, we now have clear equality objectives providing focus for our annual EDI action plans and there is a strong governance structure to embed EDI across the organisation. Other changes include the introduction of personal EDI objectives for all staff, supported by a wide range of professional development opportunities; annual collection and analysis of staff and Board diversity data; the introduction of an Associate Board Member to increase Board diversity; establishment of a larger senior management team to further improve diversity of thought in decision-making; and wider user of equality impact assessments.

Even with these numerous positive achievements, we have been deliberately self-critical in our approach to the self-assessment in order to drive further improvements. Our overall finding was that we do not yet fully meet all the expected outcomes of the EDI Standard of Good Regulation. We identified several opportunities for improvement. We need to be stronger in collecting and using EDI data across all our functions and we need to examine where there may be potential for bias in our procedures. We also want to be better at hearing public, patient and service user voices..

We believe our self-assessment was a rigorous, fair and candid reflection of where we are now regarding EDI. We publish our findings as part of our commitment to continuing progress on EDI. We will carry out a self-assessment again by April 2025, when we expect to report good performance against the Standard. We will publish the outcome of this in summer 2025.

Read our blogs

Reflections from our roundtable in Scotland: barriers to complaining

by Moi Ali, PSA Board Member | Nov 17, 2023

PSA Board Member Moi Ali reflects on our recent roundtable in Scotland where the topic discussed was "why are there so many barriers to complaining?"

It’s commonly accepted that complaints are a great source of information, highlighting what an organisation is doing wrong, and what needs to be tackled to improve organisational performance. But if organisations generally, and healthcare regulators in particular, really value complaints, why are there so many barriers to complaining? And why is so little focus placed on removing obstacles? That was a topic that the PSA raised in its 2022 report Safer care for all and the focus for the PSA’s stakeholder event in September 2023 in Edinburgh.

I thought I knew a lot about complaints, having held many senior complaints roles over the years – including, currently, being the first Home Office Independent Complaints Examiner, and also undertaking a similar role for the Crown Prosecution Service. Nonetheless, I went away with plenty of food for thought. I’d been of the view that the so-called ‘chattering classes’ (I hate that term!) – namely, the affluent and well-educated middle classes – were well represented amongst complainants, and did not face the same barriers to complaining. I shall have to question my own prejudices following one participant’s insight: some women in that category are what she termed “people pleasers”, who are reluctant to complain because of the social expectations placed on them.

That got me thinking about another awful expression: “Karens”. My own kids introduced me to this undoubtedly pejorative term: “Oh mum, stop being such a Karen,” they exclaimed when I complained about poor service in a restaurant after a family meal. There certainly is pressure on middle class women not to complain, or to be stigmatised for doing so.

It is worth considering the correlation between a willingness to complain/ability to be heard by women and the apparently high volume of patient safety scandals and incidents affecting this group. In Safer care for all the PSA highlighted that, as well as the frequent occurrence of maternity scandals, both the Cumberlege Review and the Paterson Report highlighted harm caused to predominantly female patients and the difficulties faced by those trying to raise the alarm. The Cumberlege Review described a ‘denial’ of women’s concerns.

Another insight at the roundtable in Edinburgh came from Rosemary Agnew, the Scottish Public Services Ombudsman (SPSO), on the need for child-friendly complaints procedures. Research carried out by YouGov on behalf of the Parliamentary and Health Service Ombudsman (PHSO) found that children (and younger people generally), but those from minority ethnic backgrounds, or with disabilities, are most likely to be affected by public service failures, yet least likely to complain.

Talking of the PHSO, a significant barrier to escalating complaints about Government Departments and other public bodies to this final tier of the complaints system is the requirement to have the matter referred by a Member of Parliament (MP). It would be unsurprising if the most disadvantaged (and least likely to complain) found this a deterrent. Although this doesn’t apply to complaints about the NHS which can be made directly to the PHSO (once the matter has been exhausted through other more local routes) or through an MP it still raises an interesting question about the persistence of such obstacles: Are barriers a deliberate part of rationing healthcare complaints? Discuss.

There are many possible reasons why people don’t complain. They may not realise that they can, or be unsure of how to access and navigate the complaints system. The complexity of their issue/concern may be a barrier – both understanding what went wrong and being able to articulate it. This can be magnified if there are literacy difficulties, English is not a first language, or they have special needs. People may be at a very low ebb, without the emotional energy to complain. They might be ill, or made ill by the stress. Then there’s digital exclusion, which may affect some older people, lower socio-economic groups, migrants and homeless groups.

One of the main reasons people don’t complain, even if they can, is that they feel that nothing will change as a result – or worse, they fear that access to the very services upon which they rely, the ones that have failed them, may be adversely affected if they complain. This was a theme which arose from research the PSA recently commissioned into perceptions of discriminatory behaviours in health and care where some participants feared the consequences if they raised concerns about their experiences of discrimination. This too is unsurprising, but the real challenge is how regulators can reach out to under-served communities to encourage legitimate complaints by building trust in the complaints system amongst those groups least likely to complain. It’s a big ask, but a necessary one if the profile of complainants is to change.

And what exactly is the profile of complainants? Monitoring change requires an analysis of who currently complains and, crucially, which groups don’t – and why. As the PSA highlighted in Safer care for all, the data on who does and doesn’t complain is extremely patchy, particularly demographic information, making it difficult to get an accurate picture of who is and isn’t complaining. Next, an action plan needs to be drawn up and implemented. Performance needs to be measured along the way, and plans amended as necessary. All of this takes time and money – and it takes staff. This, at a time when some of the regulators are struggling to fill fitness to practice vacancies so that complaints can be investigated and, where necessary, put before panels. Perhaps more cross-working across regulators may be part of the solution.

In Safer care for all we recommended that:

Regulators work with other health and care bodies to gain a better understanding of the demographic profile of complainants and reduce barriers to raising complaints for particular groups.
Demographic data on complaints made to the health and care services across the UK is recorded and made available for all bodies to use.

There is a role for us at the PSA in pushing for more accessible complaints systems across health and care, and for sharing best practice. As a first step, building on the discussion in Scotland, we will be holding an event with the Parliamentary and Health Service Ombudsman in January 2024. This event will bring together health and care sector stakeholders to look at what we know about the barriers that currently exist and promote practical action and solutions to address these. However, we will need to think about further steps we as an organisation can take to bring about change in this area.

I for one stand ready to support this worthwhile piece of work, so that we can start to see the demographic widen, as complaints processes recognise and remove barriers and thereby widen the diversity of those complaining.

Get in touch

Please let us know if you need our material in other formats. Email info@professionalstandards.org.uk

PSA first self-assessment on equality, diversity and inclusion

We have published our first self-assessment on EDI. The purpose of the self-assessment was to evaluate where and how we can improve EDI outcomes in our own processes and in those we oversee. We've also reflected on the progress we have made to date. See opposite for more details.

No more excuses - tackling inequalities in health and care professional regulation

This is the first chapter in our report - Safer care for all: solutions from professional regulation and beyond. we looked at the impact of inequalities on patients, service users and registrants, and on public confidence more widely. We also took a closer look at what professional regulation (and beyond) could do to tackle inequalities in health and care.

We have held two events linked to this over the last year:

On 14 December 2023 more than 90 participants joined us online to explore whether health and care professionals in the UK should have an explicit responsibility in supporting action to address these disparities as they do in other countries. And, if so, whether regulators need to reinforce such a role through their training, standards and guidance.

We then started the new year off with a joint online seminar on tackling barriers to complaints with the Parliamentary and Health Service Ombudsman (PHSO). The event followed on the heels of an earlier in-person event with patient and service-user organisations held in Edinburgh in September 2023.

The event brought together over 100 stakeholders from across the health and social care sector to discuss and explore the barriers that currently existing and can prevent patients and service uses from complaining. Along with our PHSO colleagues we wanted to share examples of innovative actions to widen and improve access to complaints services and to encourage and promote further joint work to tackle barriers to complaining. The event gave us much food for thought and we will look to continue this work in 2024/25.

You can find out more about both of these events here.