By Claudine Kapel
If your organization recently received a letter from the Ontario Pay Equity Commission regarding their Gender Wage Gap Program 2011, you know pay equity is alive and well in the province.
The Government of Ontario has decided it’s a good time to check on how pay equity is going. The Pay Equity Commission observes that the primary goal of its new Wage Gap Program is to collect sufficient data to enable it “to determine whether gender discrimination in pay practices is still prevalent.”
The commission notes that its “pilot” Wage Gap Program will “contact Ontario workplaces with more than 500 employees that have not recently been visited by a review officer.” It adds that the program “will likely be expanded to include small and mid-sized businesses.”
The challenge for many Ontario employers is that pay equity has not been top of mind in recent years. And the lack of attention could mean some pay equity issues have crept into the system, even for organizations that completed an initial filing when the provincial pay equity legislation was first introduced. If you don’t know what you don’t know, you may find yourself offside from a regulatory perspective.
Pay equity analysis is often not a core element of compensation program reviews. And the regular churn of staff over time can lead to a hazy corporate memory of how pay equity has been addressed in the past. For example, how many Ontario organizations today can easily find the documentation pertaining to their original pay equity posting from the 1990s?
Further, there is sometimes even haziness regarding who is actually covered by Ontario’s Pay Equity Act. Some smaller employers don’t realize that they become covered by the act once they hire their tenth employee.
Organizations that get audited by the commission will find themselves compelled to examine their pay practices. But a letter in the mail will likely cause fewer heart palpitations if you know where you stand and you have your house in order as a matter of practice.
If you’ve received a letter, you’ve seen that the commission is being quite rigorous with respect to the data it’s collecting – which encompasses the details of employees in Ontario, including job title, gender, pay as of Dec. 31, 2010, salary range and years of service. And the commission notes that if there appears to a gender wage gap, or if they do not receive the requested data by a specified deadline, then the employer will be referred to a review officer.
If you haven’t received a letter, that doesn’t mean you’re off the hook. The commission has been pretty clear that these are still early days for its Wage Gap Program.
To that end, some healthy introspection may be worthwhile. How would you fare if you were audited? When was the last time you tested your level of compliance? Are there any issues that need to be addressed?
Because when it comes to regulatory compliance, an ounce of prevention is worth a pound of cure.
Note: In my next blog May 2, I’ll take another look at women and pay in the article “Gender wage gap a complex issue.”
Claudine Kapel is principal of Kapel and Associates Inc., a Toronto-based human resources and communications consulting firm specializing in the design and implementation of compensation and total rewards programs. For more information, visit www.kapelandassociates.com.