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Employment Law General Update – April 2025

Employment Law

Lots of updates in this month’s newsletter. New entitlements came into force at the beginning of the month with regard to neonatal care leave and statutory pay. Whilst a survey has found LGBTQ+ employees feel unsupported by their HR teams, the government is busy investigating race and disability rights issues and asking for your help with this. A survey has been carried out looking at workplace abuse and changing trends in employment and there are some important changes to immigration and sponsorship fees and guidance from the ICO about storage of personal data.

  • Parental Leave & Pay: Government guidance on statutory neonatal care leave and pay published
  • Equality: Study finds nearly half of LGBTQ+ employees feel unsupported by HR
  • Equality (Race and Disability) Bill: government issues equality law call for evidence
  • Employment Survey: Survey highlights workplace abuse and changing trends in employment
  • Immigration: Changes to the definition of “small sponsor” will impact some sponsorship fees
  • Data: ICO publishes new guidance on anonymisation and pseudonymisation

Parental Leave & Pay: Government guidance on statutory neonatal care leave and pay published

New statutory entitlements to neonatal care leave (NCL) and neonatal care pay (SNCP) came into force on 6 April 2025. On 6 April 2025, the government published a suite of new guidance for employees and employers on NCL and SNCP:

ACAS previously published its new guidance on NCL and SNCP on 2 April 2025. Read it here.

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Equality: Study finds nearly half of LGBTQ+ employees feel unsupported by HR

On 14 April, website People Management reported that a study carried out by Pride in Leadership, a UK-based LGBTQ+ Leaders’ Community, has revealed that nearly half of LGBTQ+ employees feel unsupported by their employers’ HR departments when facing LGBTQ+-related issues. The survey of 1,017 LGBTQ+ individuals found that 42% of respondents felt that their concerns were “brushed off” by HR, highlighting a significant gap in support and understanding.

The study identified several barriers to LGBTQ+ career advancement, including a lack of inclusive workplace policies, experiences of discrimination and biased recruitment practices. Among the respondents, 85% reported that they have encountered significant obstacles linked to their identity, with a lack of representation in leadership being a major concern. Only 15% of respondents felt that their workplace was a safe space to share their identity.

To address these issues, the study calls for HR departments to take a more proactive approach to create a supportive and inclusive work environment. This includes providing training on LGBTQ+-specific issues, developing and implementing inclusive policies, and promoting diversity and representation in leadership. It also urges employers to actively work to eliminate biased recruitment practices and ensure that hiring processes are transparent and fair.

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Equality (Race and Disability) Bill: Government issues equality law call for evidence

On 7 April 2025, the Office for Equality and Opportunity published a call for evidence on equality law. The wide-ranging call for evidence seeks views and evidence on areas the government intends to address in the forthcoming Equality (Race and Disability) Bill. These include extending the equal pay provisions in the Equality Act 2010 (EqA 2010) to race and disability, ensuring that employers cannot outsource services to avoid paying equal pay, improving enforcement of equal pay by setting up a new Equal Pay Regulatory and Enforcement Unit and improving pay transparency by adopting measures similar to those in the Pay Transparency Directive (2023/970/EU).

The government also plans to bring section 14 of the EqA 2010 into force, allowing direct discrimination claims for combined or dual discrimination to be brought in the employment tribunal. It seeks views and evidence on the prevalence of combined discrimination, including how levels and patterns of combined discrimination may differ across different situations, sectors and regions, and the effectiveness of the remedies available. Evidence is also sought in relation to the prevalence of combined discrimination in relation to indirect discrimination, harassment, victimisation, and the protected characteristics of pregnancy and maternity and marriage and civil partnership, which are not currently covered by section 14.

The Employment Rights Bill will introduce the power to make regulations specifying the steps employers must take to prevent workplace sexual harassment. To assist in the drafting of those regulations, evidence is sought on measures employers can take that have proved effective in practice to reduce or prevent workplace sexual harassment. Evidence is also requested in order to assist the government in determining whether protection against sexual harassment should be extended to volunteers.

Views and evidence are also sought on the extent to which the public sector equality duty is complied with by non-public bodies exercising public functions and the effectiveness of the implementation of the socio-economic duty in Scotland and Wales, with a view to commencing the duty in England.

The call for evidence runs until 30 June 2025. You can read more here: https://www.gov.uk/government/calls-for-evidence/equality-law-call-for-evidence.

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Employment Survey: Survey highlights workplace abuse and changing trends in employment

A survey conducted by academics from Cardiff University, UCL, Nuffield College, Oxford, and the University of Surrey, has highlighted the prevalence of workplace abuse in the UK. The Skills and Employment Survey, which is conducted every six years, found that one in seven employees has experienced some form of workplace abuse, including bullying, violence, and sexual harassment. The survey revealed that some occupations, such as nursing (32%) and teaching (28%), are at higher risk of abuse, with women and night workers also being more vulnerable.

The survey also highlighted the impact of the pandemic on the way we work, with over half of workers using spaces intended for other purposes to carry out their work. The adoption of AI is also accelerating, with 24% of those surveyed using AI in their work. However, the use of AI is concentrated in high-paying, high-skill occupations, and is more prevalent among men, younger workers, and those with a degree.

The survey also found that demand for graduate-level qualifications continues to increase, with almost half of workers needing a degree for their current job. However, the number of workers with graduate-level qualifications has declined slightly. The survey also revealed a changing perception of unions, with over a third of employees in non-unionised organisations saying they would vote to establish a union if given the chance.

The researchers warned of the pitfalls and inequality involved in many employees’ working arrangements, particularly with regards to working from home. While some employees are able to create a home office, others are not, and the survey found that money and power play a significant role in determining who is able to work from home and create a comfortable workspace. The researchers called for policy to focus on promoting all forms of flexible working, rather than just working from home, to address these inequalities.

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Immigration: Changes to the definition of “small sponsor” will impact some sponsorship fees

Sponsors who are defined as “small” pay lower fees for Skilled Worker and Senior or Specialist Worker sponsor licence applications and the Immigration Skills Charge (ISC) for these workers’ visa applications.

In defining “small” and “large” sponsors, the Home Office relies on the definition of “small” and “large” companies found in the Companies Act 2006 (section 382), which changed on 6 April 2025. (See also, regulation 2 of the Immigration Skills Charge Regulation 2017 (SI 2017/499).)

The definition of a small company is based on the following three thresholds. If a company exceeds at least two of the three thresholds, it will not be a small company:

  • Number of employees: 50 (this remained unchanged on 6 April 2025).
  • Turnover: £15 million (changed from £10.2 million on 6 April 2025).
  • Balance sheet total: £7.5 million (changed from £5.1 million on 6 April 2025).

If, as a result of this change to the definition of “small company”, the sponsor company’s classification has changed from small to large or vice versa, the sponsor must notify the Home Office within 20 working days using the sponsor management system, to comply with their sponsor reporting duties. The sponsor may need to provide evidence, such as recent company accounts and a list of employees.

For more information see: UK Visas and Immigration: Workers and Temporary Workers – guidance for sponsors part 1: apply for a licence (9 April 2025) and Immigration Skills Charge Regulations (SI 2017/499).

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Data: ICO publishes new guidance on anonymisation and pseudonymisation

The Information Commissioner’s Office (ICO) has published guidance on anonymisation and pseudonymisation. The ICO notes the risks and benefits of sharing personal data, as well as the importance of anonymisation techniques to provide a privacy-friendly alternative to data sharing.

The ICO guidance provides an overview of anonymisation techniques, including their strengths and weaknesses and the suitability of their use in particular situations, including case studies. The main benefits of anonymisation include protecting people’s identities, greater security and improved risk reduction relating to the disclosure or publication of personal data.

The guidance also covers pseudonymisation, which replaces information that directly identifies people. This might include replacing names or identifiers with resource numbers. The ICO reminds organisations that pseudonymisation should not be confused with anonymisation and that pseudonymisation is a way of reducing risk and improving security but not a way of transforming personal data to the extent the law no longer applies.

The guidance also includes advice on accountability and governance measures for organisations and deals with the role that anonymisation plays in the three regimes of data protection law:

  • General processing under Part 2 of the Data Protection Act 2018 (DPA 2018) and the UK General Data Protection Regulation (2016/679) (UK GDPR).
  • Law enforcement processing under Part 3 of the DPA 2018.
  • Intelligence services processing under Part 4 of the DPA 2018.

The guidance sits alongside the ICO data sharing code of practice, which gives practical advice on how to share personal data in line with data protection law. The ICO notes that anonymisation offers an alternative way to use or share data by making sure that people are not identifiable.

Although the guidance is not statutory and there is no penalty for not following the recommendations, the ICO will take it into account when looking into an issue about anonymisation.

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Further Information

If you would like any additional information, please contact Anne-Marie Pavitt or Sophie Banks on: hello@dixcartuk.com


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The data contained within this document is for general information only. No responsibility can be accepted for inaccuracies. Readers are also advised that the law and practice may change from time to time. This document is provided for information purposes only and does not constitute accounting, legal or tax advice. Professional advice should be obtained before taking or refraining from any action as a result of the contents of this document.


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