Ontario Municipal Human Resources Association

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.

Tracking Metrics Along the Complaint Lifecycle

Employers should track metrics at each stage of the complaint lifecycle, from how concerns are raised to how they are resolved.

As a starting point, employers should track metrics that speak to accessibility and trust. For example, how are concerns being raised: through self-reports, witness reports, anonymous channels, or manager escalation? Are complaints coming from particular departments, worksites, or reporting structures? Are the same teams or leaders appearing repeatedly in the data? These patterns can help employers identify where employees feel able to raise concerns and where barriers may still exist.

At the process level, employers should assess whether complaint handling is timely, from intake through resolution. This includes tracking how long it takes to acknowledge a complaint, decide on interim measures (if any), assign or commence an investigation, complete witness interviews, finalize the investigation report, and communicate the outcome. Recurring delays may point to resourcing constraints, unclear procedural ownership, or structural bottlenecks.

That said, not all delays reflect process failures. It is also helpful to capture metrics that speak to the complexity of the investigation itself—such as the nature and number of allegations raised, the number of witnesses interviewed, whether the allegations overlap with other workplace policies, the volume of documentary evidence reviewed, and whether the conduct at issue is recent or historical. Tracking these factors alongside timeliness can help employers distinguish between delays or roadblocks caused by the inherent demands of a particular case, versus those caused by process weaknesses.

Employers should also track outcome data, as this is the foundation of any meaningful accountability assessment. This may include tracking how many matters are resolved informally, how many proceed to formal investigation, what findings are made, and what corrective actions follow.

Beyond individual case outcomes, complaint and investigation metrics can be used to strengthen equity across the harassment and investigations program as a whole. This involves reviewing data in the aggregate to ensure that complaints are received, assessed, investigated, and resolved using the same standards, and that outcomes are fair across cases. Procedural consistency can be measured by defining the core steps that should occur in every investigation and tracking whether those steps were followed across cases. Outcome fairness can be assessed by comparing the corrective action imposed in cases with comparable factual findings, and by examining whether substantiation rates vary across certain factors. For example, where disparities in either process or outcomes emerge, employers should assess whether they correlate with factors like an investigation participant’s role or seniority, or a particular complaint type—and use that data to revisit and audit those processes to drive more equitable outcomes in the future.

Start with What You Have and Build to Improve

Most of this data already exists in HR files; it just needs to be synthesized and closely reviewed. Even basic trend analysis conducted as part of an employer’s annual program review can reveal recurring issues, emerging risk areas, or inconsistencies that would otherwise remain invisible. Those insights can then be used to guide meaningful organizational change, whether through targeted training, stronger supervision, policy revision, or other measures aimed at reducing future complaints and producing more equitable outcomes. When tracked and analyzed well, complaint and investigation data becomes more than a record of individual cases: it becomes a practical tool for accountability and continuous, equity-informed improvement. That is where the metrics truly start to matter.

Written by: Inggrid Wibowo, Lawyer & Workplace Investigator, Williams HR Law LLP