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This guidance was developed by MindTribesExternal Link in close consultation with the Commission for Gender Equality in the Public Sector. The guidance includes advice on how to apply intersectionality for each of the obligations, podcasts showcasing the voices and lived experiences of women facing intersectional barriers, and case studies demonstrating practical actions.


The Gender Equality Act 2020 (the Act) requires Victorian public sector organisations to progress gender equality in the workplace and our community.

Section 6(8) of the Act outlines that “gender inequality may be compounded by other forms of disadvantage or discrimination that a person may experience based on Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes.” For the purposes of this guidance, the Commission refers to this concept as “intersectional gender inequality”.

By recognising intersectional gender inequality, the Act aims to address discrimination, disadvantage, and inequity. It encourages defined entities to create equitable workplaces and deliver services where all people are supported to be respected, safe and empowered in environments that are accessible and responsive to their unique and changing needs.

This web page includes some initial guidance and ideas for how defined entities can apply intersectionality to their work under the Act. It also includes podcasts and case studies to help you engage with the stories, challenges and opportunities of this work.

The Commission will add to this guidance, in partnership with experts and defined entities, as we learn over time.

What is Intersectionality?

The concept of intersectional disadvantage or discrimination is sometimes called “intersectionality”. It explains how people may experience overlapping forms of discrimination or disadvantage based on attributes such as Aboriginality; age; disability; ethnicity; gender identity; race; religion; and sexual orientation. Note, in this guidance, we refer to these attributes as the “intersectional attributes”.

Intersectionality recognises that the causes of disadvantage or discrimination do not exist independently, but intersect and overlap with gender inequality, magnifying the severity and frequency of the impacts while also raising barriers to support.

The concept of intersectionality was coined by Professor Kimberlé Crenshaw in 1989. In developing ‘intersectionality’ as a concept, Crenshaw cited a court case where a group of African-American women argued that a manufacturing company had refused to hire them on the basis on their race and gender. However, the court ruled that the company was not guilty of discriminatory hiring practices based on race, because they had hired African-American men to work on the factory floor.

The court also ruled that the company had not discriminated on the basis of gender, as they hired white women for office-based roles. What the court failed to consider was the intersection of race and gender and the compounded discrimination faced by African-American women.

Every person has multiple, intersectional identities. For some women, their intersectional identity may provide a degree of privilege, but for others, it may result in more discrimination. Some women are at higher risk of different types of discrimination, such as racism, class oppression, homophobia, transphobia, ageism, or ableism.

The intersectional approach suggests that tackling disadvantage in one group may not address discrimination and marginalisation experienced by all other groups equally. Therefore, work to prevent gender-based inequality cannot be completed in isolation from work to address other forms of discrimination.

February 2022

Duty to promote gender equality


Defined entities have a duty to promote gender equality when developing policies and programs and in delivering services that are to be provided to the public, or have a direct and significant impact on the public.

Defined entities should apply an intersectional gender lens when taking action to comply with this duty. An intersectional gender lens means taking a perspective that considers people’s overlapping attributes (such as age, gender, sexuality, race etc) to understand the discrimination or disadvantage they face.

Examples of work that could benefit from an intersectional gender lens include:

  • providing gender analysis training
  • developing and reviewing policies, programs, and services
  • procuring goods, services, suppliers or consultants
  • developing contracts
  • assessing the provision of funding or grants
  • recruiting, developing or promoting staff
  • developing processes and strategies
  • communicating with stakeholders and the community.

Building organisational awareness is key to gaining employee buy-in, support and engagement with proposed actions to address intersectional gender inequality. Organisations should use a multipronged approach via executives and senior leaders, employee-wide engagement, and through the voices of employees with intersectional attributes. Examples could include:

  • Executives and senior leaders should make a public commitment to build a diverse, intersectional workforce, and reduce discrimination or disadvantage. This can be achieved through a written statement on a website or a video of senior leaders committing to intersectionality, and publicly promoting current work underway that uses an intersectional lens.
  • Executives and leaders should demonstrate their commitment through role modelling inclusive behaviour and actively engaging in actions that make a tangible difference to tackling intersectional gender inequality.
  • Organisations can engage employees through initiatives that build organisational awareness of intersectionality, such as celebrating and leveraging commemorative days to create awareness.
  • Organisations can promote understanding of intersectionality and develop an awareness of biases, barriers, disadvantages, and discrimination (systemic and individual) through training programs and workshops.
  • Organisations should also review imagery and language in internal and external facing publications. This will communicate widely across the organisation that the entity is inclusive of all people with intersectional attributes.
  • Organisations should promote the voices of employees with intersectional attributes on internal forums (such as Townhalls, Panels of Speakers) and in both internal and external media. This will normalise their visibility and representation and encourage greater inclusion.
  • Organisations should support staff–led networks that provide a safe space for employees who may experience intersectional gender inequality. Ensure employee groups have executive sponsorship and provide adequate funding and other resources if they are a volunteer group.
  • Organisations need to highlight the views of their employees with intersectional attributes (with their permission) and share widely the de-identified intersectional data collected, to better inform decision-makers on staff’s experiences, and guide their responses.

Organisations can also work towards applying an intersectional gender lens to their duty to promote gender equality by strengthening intersectional community and stakeholder engagement. Examples could include:

  • Organisations should conduct meaningful consultation that obtains intersectional perspectives from within the community. Identify the groups of people with similar intersectional attributes in your gender equality stakeholder map, such as community groups representing different intersectional attributes (Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation, and other attributes).
  • Collaborative and inclusive relationships with these groups will provide insights into engagement and possible actions that can be taken. It will also allow intersectional community members to raise concerns regarding the impact of service delivery to them.
  • When engaging with community groups, ensure that appropriate feedback mechanisms are in place.



Colleen shares how to use research in the market to promote a greater understanding of women with a disability.

Michelle, a transwoman, shares in her interview, “Don’t judge me by what I am, but by who I am” and discusses how making others aware of the struggles can reduce bias.

Tanvi, identifying as a woman of colour, calls for everyone to, “Remove the Blindfolds”. Tanvi wants the real issues of women of colour to be heard and understood.

Case study

Read about how an organisation used its year-end celebrations to engage employees with intersectional attributes to share diverse stories.

  • Background

    A defined entity in the utility sector with 500 staff in a regional area, has been since 2016, actively trying to improve gender inequality in their organisation and in their community engagements. From 2016 to 2018, this entity has had a very siloed approach to diversity and inclusion, developing five “streams” of focus namely: Gender, LGBTIQA+, Aboriginal and Torres Strait Islander Peoples, Disability and; Cultural and Linguistically Diverse People. From 2016, each stream had in place a semi-active, staff-led network. From 2018-2020 substantive progress was made, on gender equality, especially with the appointment of women into two key roles (the CEO and Chair of the Board – a ‘first’ in the history of the organisation). This entity also created targets to achieve gender balance in all leadership roles by 2022.

    Challenge and Complications

    While the focus on gender equality has yielded progress since 2018 (a 4% improvement of women in senior leadership roles and a 11% improvement in management roles), a gender analysis of successful candidates has shown that this progress has not been intersectional, apart from women being representative of different ages. Entity leaders recognised that this representation across different ages, was coincidental, as there were no specific programs or initiatives to encourage applicants across various age groups. The gendered data analysis showed clearly that there have been no women appointed who identified as Aboriginal, gender diverse, sexually diverse, living with a disability, racially, or ethnically diverse.

    While entity leaders, people and culture committed in 2019 to take a more intersectional approach, the lockdown during 2020 impacted planned deliverables. Gender targets were not met, mainly due to a freeze on hiring, restructures and redundancies. While there was good intention to investigate intersectionality, working from home, along with personal pressures, inhibited volunteer staff-led networks, people and culture and leaders from moving forward.


    Towards the end of 2020, a working group comprised of people and culture leaders, members of various staff led networks, managers and leaders presented a case for change to the CEO, to make gender equality more intersectionally inclusive, leveraging the Gender Equality Act’s guidance on intersectionality. The CEO immediately approved, championed this with the Board and became the key sponsor of the working group which formed into an Equality, Equity, Diversity and Inclusion (EEDI) Council.

    The EEDI Council decided to leverage the learning from the progress on gender equality, which began with building awareness through the communication of stories to promote the organisations commitment. This aligned with the Commission for Gender Equality in the Public Sector’s (CGEPS) guidance of ‘building organisational awareness’. The learning for this entity from the CGEPS guidance was to also build community awareness and ensure visibility of gender equality in community engagements and with stakeholders simultaneously.

    Based on this learning, one of the first actions in November 2020, was to launch with the internal communications team, an employee engagement and community engagement campaign called, ‘A Very Diverse Year End’, as it was widely acknowledged that employees and the community had been through a very tough year. The EEDI Council also recognised that the usual year end campaign, was focussed on Christmas which was not intersectionally inclusive.

    Members of the staff led networks also advocated for data collection with respect to lived experiences. It was agreed that in addition to collecting data on intersectional demographics (where staff could self-identify), a key question would be added to the employee engagement survey, i.e. “What personal attribute or identity creates a barrier for you at work?”.

    It was also agreed that the entity’s 2030 Strategy for Regional Prosperity be updated to reflect a public commitment to intersectionality, post gathering of community demographic data.


    “The Very Diverse Year End” campaign run in the community and internally for employees, yielded stories that showcased the intersectional diversity and intersectional inequality experienced by employees and community members. It also revealed the lack of leadership and management awareness of these lived experiences. The stories prompted two key actions:

    • To improve the imagery and language that is publicly available.
    • To create a calendar of commemorative days to celebrate different cultures, traditions, practices and needs.

    The EEDI Council now has clear buy in from the CEO and Board Chair to focus on gender equality from an intersectional perspective, as evidenced through the public commitment made in the 2030 Strategy for Regional Prosperity. Demographic data analysis of the community revealed that there are 49% men, 51% women, 1% Aboriginal and Torres Strait Islander people, 12% Cultural and Linguistically Diverse People; and 15% living with a disability. The 2030 Strategy now links the region’s economic, social and environmental growth, to how the entity’s people are representative of the community they serve. This commitment communicates publicly that there is work to be done on improving representation and inclusion.

    The employee engagement data was analysed, especially with respect to the question on, “What personal attribute or identity creates a barrier for you at work?”. This revealed that women who identify as Aboriginal, Culturally and Linguistically Diverse and living with a disability face the most barriers to inclusion at work.

    Next Steps

    The EEDI Council along with the Executive Leadership Team have committed to the following next steps to continue to promote gender equality intersectionally:

    • Plans to engage their relevant Minister (who was also the first woman), to share the intersectional 2030 Strategy for Regional Prosperity, so that she can champion and share progress.
    • A gender impact assessment focussing on new utility connections, billing and enquiries and complaints with an intersectional focus on Aboriginal, CALD and Disability.
    • Intensive leadership training and coaching:
      • on the changing role of a leader (responsible for both high performance, equity and inclusion in the business and how people serve the community),
      • on understanding intersectional gender barriers at work.
      • on how to be vocal and visible along with women representing intersectional attributes to continuously share stories of lived experience and what can be done to remove or reduce barriers.
    • Regular internal communications focussing on equity, equality and inclusion to amplify intersectionality rather than the ‘pillared approach’.
    • Amending gender targets to include intersectionality at entry, management and leadership levels.
    • Establish EEDI Council reporting, (at least 3 monthly) into the Executive Leadership Team to ensure that there is a consistent dialogue on gender equality from an intersectional perspective.

Applying intersectionality to gender impact assessments


Applying an intersectional approach to a gender impact assessment requires thinking about the different experiences of people in the communities that your organisation serves, and considering how their experience of gender inequality may be shaped by other aspects of their identity.

You can read introductory guidance for applying intersectionality to obligations under the Gender Equality Act 2020.

Our Leading Practice Resources page contains a list of useful external resources for applying intersectionality.

Determining when a gender impact assessment is required

Organisations should apply an intersectional approach when considering what policies, programs and services require a gender impact assessment.

As described in this guidance note, this means thinking about the reach and depth of impact of your work when considering whether its impact is ‘significant’.

  • Some policies, programs or services may reach a small part of the population, but target people who may experience particular disadvantage or have particular needs – for example, services for people with disability, older people, or survivors of family violence.
  • Some policies, programs or services may have a small impact on most of the community, but impact on health, wellbeing, social, environmental, economic or cultural outcomes for a specific group or groups – for example, access to services for Muslim women or safety of LGBTIQ+ youth.

In these scenarios, a gender impact assessment is required.

Conducting an intersectional gender impact assessment

Once you have determined a gender impact assessment is required, an intersectional approach can be applied at all stages of the process. This guidance aligns with the steps in the gender impact assessment toolkit.

  • When conducting an intersectional analysis of an issue that your policy, program or service seeks to address, consider the following:

    • Avoid considering intersectional attributes (and their impacts) individually and then merely adding the impacts together. This does not produce an intersectional analysis as it does not account for the compounding effects of different attributes.
    • Try to understand the issue from the perspective of other people with multiple, intersectional attributes and how they interact or experience it.
    • Include people of diverse, intersectional attributes in the assessment team where possible.

    Typical questions to consider in your assessment:

    • What are the unique and different needs of those with intersectional attributes for service delivery and access? Are they benefitting equally? Are there any additional barriers to access for specific groups?
    • For example, what barriers will a Muslim woman, who needs to access health services during Ramadan, face?
    • Or what will an Aboriginal woman, identifying as queer and being a new parent, need from a maternal health nurse?

    In assessing the impacts of the policy, service, or program, appreciate that these impacts may vary significantly across different people within a single group, and that your own unconscious biases and assumptions of different groups of people may also unintentionally skew your assessment.

  • Determine what existing information is relevant and available, such as demographic data or research (both publicly available and from internal studies). Desktop research and case studies (Australian and international) can shape understanding of how similar policies have impacted intersectional communities, elsewhere.

    In reviewing external research, be alert to inherent biases and assumptions that exist in many studies, and often mean the voices and experiences of people with intersectional attributes are overlooked.

    Meaningful consultation gives a voice to people with different intersectional attributes and improves understanding of their lived experiences and perspectives. Consultation also helps mitigate barriers to public engagement with the policy, program, or service.

    Always consider the unique social contexts of people and provide specific and accurate information to the target audience. Consider the means of communication, making sure that all target groups can access the information including using translation services and managing the needs of people with a disability, such as hearing or vision impaired people.

  • When evaluating various possible courses of action, consider the different ways that specific groups of people with intersectional attributes may react or be affected (both positively and negatively).

    Positive impacts for one group may have very different outcomes, including negative consequences, for another diverse group with different attributes.

    For example, increased police involvement in reducing violence against women may pose a legitimate fear to some Aboriginal and Torres Strait Islander women who are concerned that greater police powers will increase their already disproportionately high incarceration rates.

    Consider whether all people will benefit from, and access, a proposed option equally. If there are variances in benefits and access, the policy option does not need to be discarded. Instead, determine what further changes will address these gaps and improve access and benefits. Use meaningful consultation to identify the impact of proposed alternatives.

  • The last step in the gender impact assessment process is to make a final recommendation based on your analyses. Explain the rationale for the proposed recommendation, including how this recommendation meets the needs of diverse people that experience intersectional gender inequality.

    When formulating your recommendation, consider the specific groups with intersectional attributes that have been identified as impacted.

    • Identify the cost, benefits, risks and mitigations specifically designed for these groups.
    • Identify the immediate recommendations that will make an impact in the first year.
    • Develop strategic recommendations that are more aspirational, and which will form part of the implementation plans for subsequent years.
    • Consider how to incorporate an intersectional approach into monitoring and evaluation.


Colleen prompts our thinking when it comes to gender impact assessments that consider the needs of people with a disability.

Aisha talks about the complications that arise with the use of interpreters and how to go about community consultations safely and positively in the Muslim community.

Nevena shares how she notices how gender-binary public spaces can be.

Case study

A TAFE decided to perform a gender impact assessment on a scholarships policy. Read how the scholarships manager provided a case for change and how the analysis revealed a lot more than they expected regarding the needs of women with intersectional attributes.

  • Background

    A newly appointed scholarships manager at a TAFE chose to conduct a gender impact assessment on the scholarship policy and process, as the published details on their website covered broad eligibility criteria but did not focus clearly on attracting diverse female applicants.

    Overall, the TAFE education sector is highly multicultural, with 1 in 8 in the Victorian youth community being an international student, with almost 50% being female. As the nature, purpose and intent of scholarships is to address inequitable access to education, the scholarships manager felt that this policy would have a ‘direct and significant’ impact on the public and as such warranted a gender impact assessment.

    Challenge and Complications

    The entire TAFE education industry is currently trying to recover financially, suffering a loss of revenue from poor international student enrolment owing to border restrictions. Consequently, this TAFE underwent a substantial restructure with resultant job losses, leaving most departments under-resourced and overworked. The introduction of the Gender Equality Act (2020) has come at a difficult period in terms of resourcing. This coupled with the scholarships manager being new, with few established internal networks makes the gender impact assessment on the scholarships policy challenging as senior leaders have emphasized that new initiatives should support business recovery.

    The scholarships manager did an initial investigation to scope the context and define the issue, as per the Gender Impact Assessment Guidelines, to ensure that they could justify their time spent on the review, to their department head. There was no central database tracking all applicants, only information on successful applicants. While the successful applicants were fairly balanced between men and women there were few applicants identifying as Aboriginal or as Culturally and Linguistically diverse.

    An analysis of scholarship sponsors revealed that they were varied: philanthropists, past alumni, families of past senior educators and other varied institutions. Some sponsors focussed on attracting women but only to a minimal degree.

    All sponsors provided funds to only support education tuition fees. There were few scholarships that supported international students with most having restrictive eligibility criteria of permanent residency and citizenship. New information showed that overall the TAFE was losing sponsors of scholarships year on year.

    The internal and external brand of the TAFE focussed on offering education and advancement to women into STEMM, construction, engineering and leadership, but this does not match the scholarships areas of sponsorship – which were generic in nature and dependent on the applicant’s chosen field of study.


    The scholarships manager decided that they needed a more qualitative understanding of potential scholarship applicants and their needs. The manager conducted an online survey sent to multiple databases of students. In addition, they used their external networks through student associations to talk with past and current student about their scholarship application experience. The manager also interviewed a few sponsors of scholarships to understand, their openness to diversifying eligibility criteria and, why some sponsors were leaving. In consultation with a few external networks, this scholarships manager positioned their focus on the gender impact assessment as encouraging more enrolments of international students when borders opened (by lining up sponsors proactively) and as supporting local students with reskilling while career transitioning.

    This would support women, who would otherwise not be able to financially support further education, and support the TAFE to increase enrolments of students who then continue their education in subsequent courses. In addition, aligning the scholarships gendered and intersectional focus would reinforce the TAFE’s brand (internally and externally) as supporting all women into STEMM pathways.

    A desktop competitor analysis of scholarships offered by other reputable TAFEs showed a gender inclusive and progressive lens on how scholarships are offered. This is a further case for change as part of their business recovery.


    The data collection and analysis helped to define and challenge assumptions to understand the context better. The main assessment was that applicants from intersectional backgrounds, who needed a scholarship, needed more than just tuition fees covered. For example, applicants living with a disability who had mobility needs needed sponsorship of accessible transport and living to ensure they could participate in learning. Migrants, refugees, asylum seekers and international students needed sponsorship of accommodation and living expenses. Transgender enrolled students needed access to funds to support their transition as this usually would mean halting education or sacrificing education to fund medical expenses.

    Interviews with scholarships sponsors revealed that they were keen on applying a gendered and intersectional lens to criteria, and were prepared to tailor their scholarship to address disadvantage, by offering it to Aboriginal; Mature Age or Young Women; Culturally and Linguistically diverse women; and women with a disability and also opening up applications to anyone who identified as a woman.

    From this process, clear options and recommendations emerged, which the scholarships manager proposed to the head of department.

    Next Steps

    Through a consultative process with a range of stakeholders, including student bodies, migration agents, TAFE communications professionals, senior leaders, managers and sponsors, the following options were agreed on and are currently being implemented:

    • Eligibility criteria now address intersectional barriers (e.g., it is now inclusive of student visas, spousal visas and other forms of visas, as opposed to only being offered to permanent residents and citizens).
    • There are now specific scholarships in place for anyone identifying as a woman and specifically women who are Aboriginal and Torres Strait Islanders, Women with a Disability, Women from a Migrants, Asylum seekers and Refugee background, Women from different life stages. The criteria of proving ‘disadvantage’ is less onerous and the scholarships now fund more than just tuition, but accommodation, living, mobility and other supportive funding, based on specialised needs.
    • There is now a direct link with scholarships targeted to encourage women applicants from disadvantaged backgrounds to enter STEMM fields, aligning the TAFE’s internal and external brand and focus.

    The public commitment to gender equality and intersectionality, due to the changes in scholarships to be more inclusive, has resulted in positive media coverage, driving an increase in TAFE enrolments.

Applying intersectionality to workplace gender auditing and analysis


Taking an intersectional approach is to workplace gender auditing is necessary to understand whether your organisation’s systems, structures, policies, and practices are working to promote workplace gender equality for all.

"Intersectional data" (in this guidance) is data that is separated by gender as well as attributes other than gender, such as Aboriginality; age; disability; ethnicity; gender identity; race; religion; or sexual orientation.

Breaking down or “disaggregating” the data in an intersectional way is important. It helps us understand how someone’s experience of gender inequality might be compounded by the discrimination or disadvantage they may experience based on other attributes.

If available, intersectional data must be used for your workplace gender audit (s11(3)(b)). If this data is not yet available, you should consider how you can collect this in the future and include this as an action in your Gender Equality Action Plan (GEAP).

In collecting, analysing and reporting this data, organisations need to be sensitive to employee safety and privacy considerations and allow employees the discretion to self-identify.

Considerations for future data collection

If intersectional data is not yet available, you should consider how you can collect this in the future and include this as a planned action in your Gender Equality Action Plan (GEAP).

You might find that your entity does not yet have the systems capabilities to collect and store some types of data. You might not yet have the culture or level of trust required to support the collection of data deemed sensitive and personal.

The best way to deal with data gaps in the immediate term is to document them in a deliberate and systematic way. Over the next reporting period, you should think about how you can improve your data collection and consultation processes to better understand intersectional gender inequality in the workplace.


The collection, analysis and reporting of data throughout the audit must be kept confidential to protect the privacy of employees.

This is particularly important when taking an intersectional approach, as the more intersectional attributes per employee are collected, the easier it becomes to identify individuals and risk their exposure.

When collecting personal information at the onboarding stage or as part of HR records, we recommend ensuring that the intention behind the collection of data is clearly articulated through a collection statement, and that questions are non-mandatory. Staff must always have the option not to disclose.

Data analysis

Analysing the data, disaggregated by intersectional attributes, will identify which groups of people should be the focus of your strategies. Furthermore, the analysis will provide insight into the systemic barriers to access, inclusion and equity for people who experience intersectional gender inequality. The results will also indicate what past actions have had the most positive or negative impact on groups with similar intersectional attributes.

Aggregated quantitative data often misses the nuances and specific concerns of people with intersectional attributes, who may become “lost” in the overall gender data. However, small sample sizes or false assumptions can easily lead to flawed data analysis, misinterpretation, and incorrect conclusions. Therefore, intersectional data should be supplemented by qualitative data analysis, to validate conclusions and ensure that less representative minority experiences are not overlooked.

As best practice, it is worth identifying any gaps in data for groups of people with intersectional attributes and if so, determine if these gaps need to be addressed immediately or in a future data collection exercise. Also consider what other metrics or measures can be substituted for the gaps in data and what improvements can be made to future data collection activities.

Quantitative analysis

Gender disaggregated data provides one option for analysing data, but without breaking this down to other demographic attributes such as age or cultural background, the specific issues and concerns of people with intersectional attributes may not be visible.

To assist with intersectional quantitative data analysis, organisations should:

  • Conduct data comparisons – comparing the data of people with intersectional attributes against the data of men and women who represent the majority. Comparisons will help you identify unusual patterns and trends in the data.
  • Consider the sample size – when data is disaggregated by intersectional attributes, the sample size will decrease. Calculating the “margin of error” of the sample size, for each group being reviewed, will help avoid drawing incorrect conclusions and exaggerating effects based on a small (statistically insignificant) sample size. For example, if 1 of 2 Indian women with a disability in a department of 100 people have experienced discrimination. To present the findings as: “50% of Indian women with a disability have experienced discrimination”, would misrepresent the actual situation.
  • Conversely, do not assume that there are no underlying issues if the results appear to be insignificant or within the margin of error, as the sample size may be too small.

Qualitative analysis

As far as possible, use diverse sample groups that represent the many people with intersectional attributes, to ensure that different perspectives are considered. As required for the GEAP, engage in meaningful consultation with communities, peak bodies, and other external stakeholders of representative groups to gain their unique perspective and represent the voices of those with lived experiences.

Always focus on “what was said”, not “who said what” when analysing commentary to determine major themes and correlations.

Ensure psychological support is available

It is important that individuals feel psychologically and culturally safe in sharing data that reveals their intersectional attributes. (Psychologically and culturally safe means being able to represent your true self without fear of negative consequences for your mental and emotional health or career.)

In some cases, your data analysis will identify ‘good news stories’. In other cases, your analysis will identify current and/or longstanding gender and intersectional inequalities. Regardless of your findings, it is important to remember that work on gender equality can raise issues for anyone in your organisation, at any time.

Whenever you discuss issues of gender in the workplace, remind employees of your Employee Assistance Program and other local support services available to them. Having appropriately skilled staff who can respond to disclosures and refer people to services as part of your consultation process is also important. Access to psychological support for those who engage in the analysis process is also an important consideration.



Amanda, an Aboriginal queer woman, discusses the challenges of asking Aboriginal and Torres Strait Islander people to identify when collecting data.

Case study

Read the case study to understand how an organisation took steps to improve their intersectional data collection and mobilised internal communications to communicate with staff about data.

  • Background

    Considering their obligations of the Gender Equality Act, a large Health defined entity decided to focus on the data collection effort, as they realised that the only source of data they have, from their payroll system, only collects data with “men” and “women” identifiers.

    The payroll system has not been set up to collect any other intersectional identifiers, i.e., there is no demographic data on Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation or other attributes. Based on the data available the defined entity has 75% of their staff, identifying as women and 25% identifying as men. Men are disproportionately in the most senior roles while there has been gender balance achieved in executive and leadership roles, as a result of deliberate succession planning and advancement. There is a recognition in the industry that a health care worker is gender stereotyped as a woman. While the industry is seeing growth in workers who identify as women who are culturally and linguistically diverse and Aboriginal and Torres Strait Islanders, this defined entity recognises that these women with intersectional attributes are not represented in management and leadership, as is evidenced from their organisational charts.

    Challenges and Complications

    A key challenge identified by this entity when approaching their data collection; is resourcing and senior stakeholder buy-in, considering the impact of the months of lockdown and disruption to the public health system, in Victoria. The resourcing and capability for an intersectional data collection and analysis is a major concern, as the D&I team is limited to one senior consultant, a graduate, and a trainee – no one has this expertise. An added contextual complication is that intersectionality has been addressed within the Diversity and Inclusion policy with distinct plans per intersectional attribute. There are separate plans for Aboriginality, Cultural and Linguistic Diverse People, LGBTIQA+, Age and Disability. As the Gender Equality Act requires the defined entity to address Intersectional Gender Inequality, the Diversity and Inclusion Policy will need to be amended.

    A further complexity is the definition of “employee” for this defined entity, as it has an ‘internal’ workforce and an ‘external’ workforce delivering the service - made up for a range of employee types (full-time, part-time, casual or fixed term basis as well as apprentices and trainees). The act shares that the scope of the data collection should go across all these employee types, making the intersectional data collection a challenge.

    There has been an attempt to collect intersectional data but on a volunteer basis via staff surveys. (In 2019, data collection efforts focused on disability and LGBTIQA+ identities; in 2020, data collection focused on ethnicity and Aboriginality.) All previous attempts yielded a low response rate. The reasons for the low response rates were investigated through staff-led network (formal staff networks of people with similar intersectional attributes) consultations, revealing a mix of survey fatigue and low levels of trust and concerns of psychological and cultural safety. The defined entity recognised that the People Matters Survey had a better response rate, being anonymous.


    This defined entity decided to mitigate the low resources in D&I team by forming two Gender Equality Action working groups, one focussing internally and one focussing externally. There was an expression of interest campaign endorsed by an Executive Director to form the two working groups - resulting in a representative from every department. These two working groups have designed a communication plan with a ten-minute regular time slot in every executive’s meeting agenda, to share information on what is needed to prepare for and execute the data collection. Early wins included securing a full-time data scientist, through joint funding across department heads and securing project-specific capacity from others skilled in data collection and analysis.

    Using the seven workplace gender audit measures table provided by the Commission for Gender Equality in the Public Sector, the working groups and data scientist, initially assessed whether data was available on gender composition and by occupation, including the Board; gender pay gap, sexual harassment complaints, attrition data, promotion data, training data, proportion of employees with formal flexible work arrangements, and those accessing parental leave, family violence leave, carers leave. While this gender data was available, very limited data was available on intersectional attributes of Aboriginality, age, disability, ethnicity and race, religion and sexual orientation.

    This defined entity has now provisioned in its budget for its payroll and other data systems to capture intersectional attributes to help future data collection. To understand intersectional gender inequality at this time, the defined entity hired an expert in qualitative data gathering (focus groups and interviews) and together with Pride, Women of Colour, Aboriginal and Torres Strait Islander and Ability Networks, arrived at key themes to address in its Gender Equality Action Plan, such as, cultural safety, gender ethnic pay gaps, downward carer mobility, underemployment, pigeon-holing in certain roles (e.g. community or specialist roles, like Indigenous Specialist).


    • The skilled data project resources have ensured that the defined entity’s data storage and security is compliant and of a high quality, accuracy and confidentiality.
    • The internal communications team was engaged to create a fortnightly email to communicate topics like, “why the defined entity is undertaking the gendered data collection process”, “how the data collection will help with the GEAP”, and “how to get involved in the consultation process”, once data has been analysed. These messages were communicated via senior leaders and staff-led networks Chairs to the relevant forums.
    • The D&I Policy has been reviewed and provisionally edited to ensure that there is a placeholder for the outputs of the gender equality audit and intersectional qualitative data. This will ensure that this policy is up to date.
    • The data collection phase has been completed and the data has been provisionally analysed by the two working groups, revealing gender inequalities (including, but not limited to):
      • All women with intersectional attributes, in permanent part time roles suffered downward career mobility more than any other group.
      • Women of colour rarely took up flexible leave for fear of backlash to their careers.
      • Aboriginal women were segregated into community and indigenous specialist roles that are lowly paid.
      • Women with a disability and gender diverse women experienced bullying and harassment more often than other demographics.
      • Older women were disproportionately represented in casual roles, as they needed to work past retirement.

    Next Steps

    The working groups and the executive leadership team are meeting to finalise the results of the workplace gender audit and will use the insights and analysis as the basis of their Gender Equality Action Plan.

Applying intersectionality to Gender Equality Action Plans


Defined entities will continue to develop and refine their implementation plans to make meaningful progress across the key indicators over the next four years. The following information provides some guidance to support organisations to progress their work by considering intersectionality in ongoing consultation and adapting strategies and measures across key indicators.

  • Once the workplace gender audit data has been analysed using an intersectional approach (described in the section above), organisations should ensure this is appropriately reflected in the GEAP.

    Your workplace gender audit results may reveal insights about people for whom gender inequality may be further compounded by disadvantage or discrimination based on Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes.

    It is important to analyse these results to understand the organisational factors that may cause intersectional gender inequality. These insights will assist in the development of future relevant strategies and measures to address any identified trends, and in a way that is sensitive to the safety, privacy and interests of people who experience intersectional gender inequality.

    It is important to consult with employees who experience intersectional gender inequality or relevant external people or groups about how to outline these insights in a safe and constructive way.

  • You must consult relevant governing bodies, employees, and employee representatives and share the results of your workplace gender audit to understand their perspective, assess the impact of any issues raised and facilitate feedback on proposed actions.

    Consultation can also guide the development of an implementation plan, improving the likelihood of buy-in by impacted employees, for any actions.

    To support intersectional voices to be uplifted in consultations, organisations should:

    • Provide safe spaces for employees to openly share their perspectives confidentially, trusting the processes and people involved, without fear of consequence.
    • Support and leverage staff-led networks for diverse employee groups to ensure employees are aware of consultation opportunities.
    • Share de-identified intersectional data as part of consultations with all groups.
    • At the start of any engagement, clarify the intended use of the information collected and clearly state how the information will be treated.
    • Provide regular progress feedback to the groups who have been engaged to ensure that they are comfortable with how their information is being used and build the mutual trust needed for future engagement.
  • You should state how intersectional gender inequality has been considered in the development of your GEAP. This may be through highlighting:

    • why intersectional gender equality is important for the organisation
    • what your defined entity has identified as the systemic barriers to access, inclusion and equity for people who experience intersectional gender inequality
    • how you consulted with and incorporated feedback from people who experience intersectional gender inequality and any other relevant organisation such as a peak body or representative organisation
    • insights relating to people who experience intersectional gender inequality, identified through your workplace gender audit or through other means
    • strategies and measures relating to intersectional gender inequality in your GEAP
    • how the GEAP complements other strategies and policies in the organisation that relate to other employee attributes, for example a disability inclusion strategy.
  • Insights relating to people who experience intersectional gender inequality, identified through your workplace gender audit or through other means will inform the development of strategies and measures relating to intersectional gender inequality in your GEAP.

    This may include specific strategies or targets for intersectional groups across the workplace gender equality indicators such as:

    • Establish a mentoring program for women of colour (Recruitment and promotion practices in the workplace)
    • Review and improve leave policies for all forms of caring responsibilities (for example, kinship caring) and conduct education with managers to increase awareness (Flexibility, leave and supports for people with family and caring responsibilities)

    Consider if the intersectional issue you are seeking to address is a widespread issue. If so, researching and reviewing strategies that have been effective for other organisations may assist in identifying the best approach.

    Review potential strategies with representative external groups, and employees with intersectional attributes, to understand whether these strategies will be met with engagement, acceptance, or resistance.

    Some employees within a group may require a different, nuanced response, as all employees in a group will not be impacted by, or respond to, an issue in the same way. Consultation will help identify any barriers that may arise in strategy implementation and, determine what mitigating actions or alternate strategies can be taken.

  • Always include people with intersectional attributes on any task force or strategy team addressing intersectional issues related to them.

    Including a wide variety of key influencers with intersectional attributes, that represent different levels, departments, and divisions of your organisation, will ensure that you have a diversity of perspectives. GEAP champions in these groups can also be advocates who promote adoption and acceptance of the strategies developed.

  • Including people with intersectional attributes as stakeholders (both employees and external representative groups) who contributed to the GEAP, will foster trust, and improve re-engagement. Stakeholders who are engaged can help identify lack of progress or community opposition and assist to adjust course in the roll-out of the strategy. Sharing progress with these stakeholders will also promote accountability and action from the implementers of the strategy.

    Consider how implementation and impact of intersectional strategies will be measured, including a combination of quantitative and qualitative data.



Amanda calls for senior leaders to succession plan and promote Aboriginal and Torres Strait Islander women into their roles within the next 5 years.

Heather discusses how identified gaps, for example where older women are being excluded, should be addressed with actionable plans.

Nevena suggests better training for HR staff on how to handle harassment complaints from trans and gender diverse women.

Case study

Read how this defined entity, responsible for urban planning, followed the 6-step process to complete their GEAP and how they worked through their Gender Equality Audit Data.

  • Background

    This defined entity is responsible for urban planning and has over 200 employees. This defined entity’s purpose is to deliver a healthy environment that supports a liveable and thriving Victoria. They have formed a project team to deliver on the obligations of the Act. The team has named this work “The Gender Equality Project”. They have briefed staff that this project offers an understanding of the barriers to diversity and inclusion and will use this understanding to introduce meaningful actions to address gender inequities for all staff. They have shared that the project’s products seek to address the impact this has on women’s career advancement, economic security and job satisfaction. Early staff consultations revealed that staff felt strongly that the needs of women with regards to Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and other attributes needed attention, as this had not been done in the entity’s history. The project team agreed that this was a critical need and it aligned with the Gender Equality Act guidance.

    The project team has outlined four (4) phases of work (see below) and are up to phase three (3): Consultation with stakeholders to develop the GEAP.

    Phase 1 – Planning

    • confirm objectives, timing and scope of work
    • develop a project plan including agreed timeline of deliverables
    • collaborate with key stakeholders to understand data gaps
    • collect any relevant organisational materials/resources to support the project (this defined entity used the gender equality principles, as outlined by the Gender Equality Commission) to link their documentation and messaging.
    • develop a communication plan
    • communicate with key stakeholders regarding project process
    • develop and facilitate short sharp training to improve capability of key stakeholders.

    Phase 2 – Prepare Gender Audit including analysis

    • gain support from internal departments to develop a privacy assessment and protocols
    • obtain data collection and extraction support
    • secure resources for data cleaning and meaningful data analysis of workforce and employee experiences
    • prepare audit outcomes report.

    Phase 3 – Conduct stakeholder consultation and develop GEAP

    • set up and facilitate consultation activities, including workshops or surveys
    • collate, synthesise and document outcomes to support the development of GEAP.

    Phase 4 – Develop Gender Impact Assessment Framework (or similar) and tools and training to build employee capability

    • partner with key resources to help in the build of a GIA framework or process
    • develop and facilitate GIA user capability training
    • design GIA process support resources to help upskill employees.

    Challenge and Complications

    The defined entity had a gender equality strategy and the initial assumption was that this strategy would be updated with the workplace gender audit data inputs, analysis and insights to form the GEAP.

    However, the workplace gender audit has revealed some surprising and different results, as this was the first time that data collection was done intersectionally, to understand the lived experience of Aboriginal and Torres Strait Islander women, women of colour, women with a disability, women across different ages, religions, faiths, sexualities and gender diversities.

    As a result of the focus groups that were conducted with Aboriginal and Torres Strait Islander women and women of colour for this data collection process - women have for the first time become vocal about their lived experience of being minorities in the workforce, experiencing slow career mobility.

    • Muslim women have shared that there has been a lack of suitable prayer rooms and understanding of Islamic faith and practices, especially during Ramadan.
    • Shortly after focus groups were conducted, there have been two complaints of bullying and harassment lodged, linked to racism; one internally and one to the Union. These are the first of these types of complaints that this defined entity has had to deal with.


    The project team followed the 6 steps process to complete their GEAP, as outlined by the Gender Equality Commission guidelines, however were successful in completing Steps 1, 2 and part of step 3, with a view to completing the rest within the next 2 months, with further in depth consultations.

    With regards to building in the workplace gender audit input and having meaningful consultation and engagement (Steps 1 & 2):

    • The project and senior leadership team met to discuss the initial analysis of the workplace gender audit and the two complaints. They agreed that the duty of care of the complainants was of the utmost importance in the light of the work on the Gender Equality Project’s purpose and the Act.
    • The project team members, many of them with lived experience, being women of colour, highlighted that the complaints process should also be assessed as part of the actions within the GEAP. These women also raised that any potentially personal, identifying information needed to be removed to protect women’s privacy and confidentiality (especially Muslim women), but that the intersectional barriers shared needed to be included in the GEAP.
    • The group also identified that the intersectional attributes needed to be included in the defined entity’s people systems for easier future data collection.
    • The defined entity’s data analytics team also shared that the ABS statistics utilised to understand Victoria’s diverse population needed to be included in the GEAP, as this data guided the thinking for the GEA and the upcoming GIA.
    • Another document earmarked to be included in the GEAP submission was the project team’s communication plan, which included Board presentations, regular staff and union consultations.

    With the case for change (step 3), the PR and Communications team compiled a history of the defined entity’s past efforts to achieve gender equality. They also made the link to the gender equality principles in their phase 1 planning process. Their case for change documentation linked their purpose of ‘delivering a healthy environment that supports a liveable and thriving Victoria’ specifically to the following principles:

    • all Victorians should live in a safe and equal society, have access to equal power, resources and opportunities and be treated with dignity, respect and fairness
    • gender equality benefits all Victorians regardless of gender
    • gender equality brings significant economic, social and health benefits for Victoria
    • advancing gender equality is a shared responsibility across the Victorian community
    • gender equality is a human right and precondition to social justice.


    The project team and the senior leadership team have achieved a draft GEAP utilising the output of the GEA, including a focus on intersectionality. While there is significant work to complete to get the GEAP ready for submission, there is buy-in and support from the Board, senior leaders and staff that this work is providing meaningful understanding and actions to address gender inequities that will improve everyone’s work experience. The project team agreed to include the following activities within the GEAP, that addresses issues raised through their audit results:

    • The established Women in Leadership Staff Led Network to include women with intersectional attributes, especially women of colour who experienced downward career mobility.
    • HR staff to receive training on responding, investigating and managing racism complaints.
    • A Calendar of Days/Weeks of significance like IDAHOBIT Day, Pride Week, NAIDOC Week, Cultural Diversity Week will be curated and observed as a way to build awareness and education and promote intersectionality.
    • All physical spaces to be designed with an intersectional lens (unisex bathrooms, chest feeding rooms, prayer rooms).

    Next Steps

    The PR and communications team are working closely with the project team on writing a vision statement (part of step 3) for what gender equality would look to look like for their organisation in four years. They are utilising the GEA analysis, the gender equality principles and indicators, as well as how the organisation plans to meet gaps relating to Aboriginality, age, disability, ethnicity, gender identity, race, religion, sexual orientation and/or any other attribute. A draft statement will be formulated for approval by the Board and senior leadership team. This will need to go through several consultations before it is approved. There will also be a Townhall held, virtually, to share what this vision looks like.

    The HR representatives on the project team are working through all the strategies and measures relating to pay, sexual harassment, recruitment and promotion practises, terms, conditions and practices related to family violence leave, flexible working arrangements, carers leave. They are focussing on the intersectional impacts that were derived from the GEA data on these existing practices and policies, but also the critical insight revealed of work occupation segregation and composition for women of colour and women with a disability. (Step 4).

    Leaders are currently being engaged on how the continuous development of the GEAP and implementation of the plans will be resourced. The project team was an interim team put together to achieve the deliverables for 2021, until mid 2022. (Step 5).

    A sub-group of the project team (made up of reporting experts) are specifically working on how progress on the GEAP will be tracked, communicated and written in a timely manner, to align with other strategic reporting internally, to the Board and publicly. Key templates are being designed to make the tracking, reporting and communicating easier year on year (Step 6).

Reviewed 23 March 2022