1  The Royal College of Pathologists (“the College”) is committed to eliminating discrimination and encouraging diversity amongst the College’s staff, its Trustees, Council, Fellows and membership and trainees, including those sitting the College’s exams (together the “RCPath community”). Our aim is to be truly representative of all sections of society and that all those involved in the RCPath community feel respected and able to give of their best. This policy does not form part of any employee’s contract of employment and the College reserves the right to amend it at any time.

2  To that end, the purpose of this policy is to demonstrate commitment to and compliance with the Equality Act 2010; to provide equality and fairness for all in the RCPath community; and not to discriminate because of age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex and sexual orientation. The College opposes all forms of unlawful and unfair discrimination.

3  All members of the RCPath community, including those wishing to join it, will be treated fairly and with respect. As stated in the RCPath Recruitment and Selection Process and the RCPath Training and Development Plan, selection for employment, promotion, training or any other benefit will be on the basis of aptitude and ability. All members of the RCPath community, where appropriate, will be helped and encouraged to develop their full potential. The talents and resources of the whole RCPath community, where appropriate, will be fully utilised to maximise its efficiency and standing. All members of the RCPath community are to comply with this Equality Policy.

4  This policy sets out the steps that the College is taking to promote equality of opportunity and ensure that they work effectively. This policy should be read in conjunction with the Recruitment and Selection, Harassment, Learning and Development and Induction policies and Disciplinary and Grievance Procedures.

5  Within the RCPath community, the College’s commitment is:

5.1  To create an environment in which individual differences in and the contributions of all parts of the RCPath community are recognised and valued.

5.2  To maintain a working environment that promotes dignity and respect to all. No form of intimidation, bullying or harassment will be tolerated.

5.3  To ensure training and/or development and/or progression opportunities are available to the RCPath community, where appropriate.

5.4  To ensure equality of opportunity in the RCPath community, which reflects good management practice and makes sound business sense.

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5.5  To ensure continued fairness, to review every three tears or earlier if there is a legal imperative:

  all our recruitment and employment practices and procedures

  our examination content and examination processes, fees and procedures

5.6  To take breaches of equality policy, which should be raised through the College’s Grievance or Complaints Procedures, very seriously and to reserve the right to apply the Misconduct Policy, which could lead to the institution of disciplinary procedures. Should RCPath Community members feel they have suffered discrimination; they should report this to their line manager or to the HR and Development Manager in the first instance. There will be no victimisation of retaliation in any form against anyone who complains of discrimination. Such claims will be fully investigated.

5.7  To ensure that this policy is fully supported by Trustees, Council and College staff, who are to receive appropriate Equality and Diversity Training, and is understood within the other sections of the RCPath community.

5.8  To monitor and review this policy every three years or earlier if legislation changes. Compliance with this policy will be audited by continuous reporting in the Forward Plan on a quarterly basis.

5.9  To respect the confidential nature of a member’s personal details and ensure they are held on the secure College database, financial systems and College intranet, in accordance with data protection requirements, and College policy on IT security. The College only uses such information for the purpose of communicating with members on relevant matters or for administration purposes.

5.10  To respect the wishes of those members who do not wish to be contacted by the College via certain means. Furthermore, the RCPath will only verify membership of individuals to outside bodies, with their express permission or where legislation demands such disclosure.

5.11  To only discuss members’ details over the telephone once we have verified the caller’s identity. Member information held by the College may be used for the College’s own statistical analysis purposes. Individual members’ details will not be disclosed as part of this purpose.

5.12  To ensure that sensitive personal and financial details of members are only to be accessible by RCPath staff with an authorised need.

5.13  To ensure that the RCPath Expenses Policy takes into account the duration of stay, distance travelled and any special needs of claimants so as not to discriminate against those who can or cannot attend meetings or take an active role in the life and work of the College.

5.14  To ensure the publication and maintenance of a College Equality Action Plan, including the nomination of Equality Champions in where this is practical committees and other decision- making fora.

5.15  To consider and record equality impacts in all College decision-making process outputs, including day-to-day procurement and contract letting.

5.16  To ensure that meetings, examinations and diverse other College activities are scheduled to take into account religious or belief-related events, where this can reasonably be done without adversely affecting the operations of the College. 

7.1 The College Membership and Finance Department receives regular reports from the profession’s regulatory bodies highlighting disciplinary proceedings against individuals, which are then matched against our database. Any such members are then flagged in confidence to the Chief Executive, members of the SMT and the Trustee Board where appropriate for assessment/action, and a note is included on the member’s database record.

7.2 Fees are set each year by the Trustee Board, so as to ensure the financial commitments of the College’s work are met. The annual subscription payable is based upon an individual’s membership grade and, for overseas members, their banding structure.

7.3 The College recognises the differing wealth of overseas countries and has classified them into four bands according to per capita income, based on the latest World Bank figures, and members will pay a rate dependent on the band in which their country of residence is located. Country bandings can be viewed on the College website, currently under ‘The College Subscription fees’ section. These bandings are reviewed periodically and any necessary changes that will affect future fees paid by overseas members will be amended accordingly.

7.4 The College also seeks further to minimise discrimination on the grounds of income by offering various discounts for certain qualifying UK-based members who are on maternity/paternity leave in the relevant year, or are in hardship. This also includes trainees registration fees where it is deemed appropriate by the SMT. 

IT: All reasonable adjustments to equipment – including telephones, ICT hardware and

software – will be made to allow any employees with a disability to give of their best.

Data: To help us monitor our compliance with the Equality Act, we may collect and store data relating to some of the protected characteristics of our members. Members will not be obliged to supply this information but may submit it to us at their own discretion as part of the application process for examinations and/or membership. In accordance with the Data Protection Act, such data will be treated as ‘sensitive’ and will only be accessible to those staff directly responsible for administering applications. This data may form the basis of anonymised reports showing aggregate statistics, but we will never share non-anonymised information about ethnic origin with a third party unless we have explicit consent to do so from the member concerned. 

The College undertakes the following:

To value diversity, by creating a Regional Network that harnesses the different

perspectives and skills of all College Leads and devolved nations’ Councils.

• To allocate resources fairly across the RCPath English regions and to support Regional College Leads and devolved nations’ Councils to help avoid ‘engagement fatigue’.
• To identify equality-related impacts regarding the management and analysis of regional information, including risks and how they are to be reported, and to escalate any concerns to the appropriate College committee.
• To foster good relations between people within regional stakeholder groups who share a protected characteristic.
• To ensure that regional content on College communication channels meets relevant standards and expectations. 

All reasonable adjustments to working areas, furniture, catering and facilities equipment will be made to allow those employees who are pregnant or with a disability to give of their best. In addition, for delegates attending our conferences, members attending Committee meetings, external clients and RCPath staff, RCPath will do the following.

• Recognise and accommodate all special dietary requirements (kosher, halal, coeliac, etc.)
• Provide hearing loops, disabled lift access and make all and any reasonable adjustments as may be required, subject to the constraints that may be imposed by building regulations, for example listed status. 

• All meetings will be scheduled to take into account religious or belief-related events where this can reasonably be done without adversely affecting the operations of the College. 

The potential impact of any proposed changes to the curriculum and/or assessment systems (including examinations and workplace-based assessments) to trainees, trainers, examination candidates, examiners and any other relevant individual with regard to the provision of equal opportunities to all will be considered by the appropriate individuals and committees within the College. The consideration of such changes will be sufficient to demonstrate that the College has addressed the issues of equality and resulting data/reports may be shared with the appropriate regulator, along with decisions made.

In particular, the College undertakes the following:

9.1  To consider ‘reasonable adjustments’ for declared pregnancy or disabilities that may affect candidates’ performance in an examination.

9.2  To ensure that, wherever possible, any protected characteristics of candidates will not be identifiable during the examinations process and that candidate information will not be used in a way that may facilitate direct or indirect discrimination against candidates.

9.3  To use the data collected about candidates and examiners in order to monitor the examinations to ensure that candidates with protected characteristics are not directly or indirectly discriminated against and to take appropriate action where this appears to be the case. Anonymous data may be used within any published information.

9.4  To ensure that the College’s examiners receive equality and diversity training.

9.5  To ensure that the College follows any direction given by the GMC (or any other regulator) with regard to equality and diversity. 

10.1  Publishing and website: The College undertakes the following.

• To review its publications and offer options for other formats, such as larger print, on request.
• To ensure that there is good and appropriate representation of a range of people from the RCPath Community and outside in the photographs we use.
• To ensure that it uses a range of case studies if we need them to illustrate press releases, pamphlets or the website.
• To review the language we use in our published documents to make sure it is inclusive and straightforward and amend our style guide if necessary. 

The College undertakes the following:

11.1 Continuing professional development (CPD)

• To apply agreed standard procedures and criteria to CPD annual return processing and the review of CPD quality activity that ensures that uniform criteria are applied to all participants. Staff will not have access to data about the protected characteristics of individuals.

11.2  Workforce

• To ensure that all potential College appointed assessors at Appointment Committees have undertaken equality and diversity training prior to acting as an assessor on the suitability of candidates for employment at consultant level.
• To provide answers to frequently asked questions relating to consultant-level appointments to enable assessors to carry out their role.

11.3  Professional standards

• To ensure that all potential College-appointed reviewers have undertaken equality and diversity training prior to acting as a reviewer.

11.4 Revalidation

• To ensure that all queries received by the revalidation advisory service are anonymised by staff prior to circulation to advisers for formal response, in order to ensure confidentiality and to eliminate bias in the response.

11.5 Conduct

• To ensure that, unless it is pertinent to the issue under consideration, the protected characteristic of any members are not revealed or taken into account when considering any case.