For OMHRA, Inggrid Wibowo wrote about how employers can better assess the effectiveness of their workplace harassment and investigation programs by tracking meaningful data and provides a preliminary framework on how to do so. As Inggrid explains, reviewing this data with a critical eye can help employers meet legal obligations, improve procedural fairness, and drive more equitable workplace outcomes over time.
See an excerpt below:
Measuring What Matters: A Data-Driven Approach to Workplace Harassment and Investigations
While many organizations have implemented workplace harassment and investigations programs, few have taken the time to assess the effectiveness of these programs through measurable metrics. Often, there is a hyperfocus on headline numbers, such as the number of complaints received or investigations completed. However, a more telling measure is whether the program is accessible, responsive, and capable of driving improvement—and answering that requires employers to collect and review meaningful data about how the program operates in practice.
The Legal Case for Data-Driven Program Review
Measuring the efficacy of a harassment and investigations program serves both governance and legal compliance objectives. Ontario’s Occupational Health and Safety Act requires employers to review their workplace harassment program as often as necessary, and at least annually, to ensure that it adequately implements the policy. The Ministry of Labour’s Code of Practice also requires an employer to conduct a review whenever “gaps or deficiencies in its program are identified as a result of an investigation”. In other words, the statute contemplates an ongoing obligation to monitor, assess, and adapt, and that obligation is difficult to meet in a meaningful way without reliable investigations data.