The information on the portal can be updated at any time (for example, if an employee develops a disability). Aside from gender, the data is treated as confidential and is not visible to line managers. The data is used to analyse progress towards targets, especially ethnic diversity at different levels.270 RBS realised ethnic minorities were underrepresented at higher levels within the bank – 11 percent of staff are from an ethnic minority group, but this falls to 8 percent across the top four levels of the organisation. Examining the data has led to greater insight about the challenges employees face as well as highlighting the scale of underrepresentation at management level. RBS has now set a target to reach 14 percent ethnic minority leaders by 2025.271 The data the bank collects is not only used to monitor recruitment but also to identify talent and ensure that progression and promotion practices in the bank are not (unconsciously or consciously) favouring certain groups. The bank actively encourages interviewers to challenge themselves and to identify any unconscious bias in the shortlisting process – over 80 percent of RBS staff have undertaken unconscious bias training.272 Ethnic pay gaps cannot be identified or closed if there is an absence of data to show this. Effective action requires organisations to establish the current landscape of where they stand today, set aspirational targets for what they expect their organisations to look like in five years’ time and measure progress against those targets annually.273 38 Furthermore, several jurisdictions internationally have also expanded existing legislation aimed at gender pay equity to encompass ethnicity or are considering doing so.274 There are increasing indications from Aotearoa New Zealand and abroad that gender pay gap laws provide a basis to model ethnic pay gap laws where much of the ethnicity pay equity legislation explored above was initially developed upon existing gender pay equity legislation.275 Several of the recommendations made by literature from the UK lend themselves to this generalised pay equity policy. However, the simultaneous need for legislation and policy targeted specifically to ethnicity is also stressed.276 In addition to legislation, large international companies are increasingly opting to create policies internally that address gender and ethnicity pay gaps. 6.1.1 Comprehensive pay transparency Pay transparency commonly includes a combination of different rules and policies such as banning employers from requesting a prospective employee’s wage or salary history, requiring that job advertisements include the expected compensation for the role and forbidding pay secrecy.277 There has been a widespread focus on implementing pay transparency legislation as a way to close pay gaps.278 A significant contributor to ethnicity pay gaps is structural racism, which impacts pay and upward career progression through institutional habits present from the point of recruitment. Therefore, the literature suggests that pay transparency legislation 270 Adams et al., Measuring and Reporting on Disability and Ethnicity Pay Gaps, 117. 271 Adams et al., Measuring and Reporting on Disability and Ethnicity Pay Gaps, 117. 272 Adams et al., Measuring and Reporting on Disability and Ethnicity Pay Gaps, 117. 273 McGregor-Smith, Race in the Workplace. 274 Equality and Human Rights Commission, Fair Opportunities for All, 25-26; Employment and Social Development Canada, Employment Equity Act, 3; Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America); New Zealand Human Rights Commission, Equal Pay and Pay Equity, 5-6. 275 In Aotearoa New Zealand: Public Service Commission. Guidance Measuring and Beginning to address Māori and Ethnic Pay Gaps in the Public Service. Wellington: Public Service Commission, 2021, 2. https://www.publicservice.govt.nz/assets/SSC-SiteAssets/Workforce-and-Talent-Management/Guidance-Measuring-and-beginning-to-address-Maori-and-ethnic-pay-gaps-inthe-PS.pdf. Abroad: Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 41-42; Equality and Human Rights Commission, Fair Opportunities for All, 25-26. 276 Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 41; Equality and Human Rights Commission, Fair Opportunities for All, 25-26; Brown, Duncan. “Gender Pay Gaps, the UK Experience: How Do We Close Them, How Do We Bring Research Into Practice?.” Compensation & Benefits Review 51, no. 4 (2019): 153. 277 Coghlan, State Policy Strategies for Narrowing the Gender Wage Gap, 1. 278 Employment and Social Development Canada, Employment Equity Act, 51-52; Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America); New Zealand Human Rights Commission, Equal Pay and Pay Equity, 1; Chifley Research Centre. Closing the Gender Pay Gap. Kingston: Chifley Research Centre, 2019, 20. https://www.chifley.org.au/publications/closing-the-gender-pay-gap/.