In this blog, Penny Babb, Head of Policy and Standards at the Office for Statistics Regulation, discusses her experience of refreshing the Code of Practice for Statistics.
As we’ve recently released the third edition of the Code of Practice for Statistics, I am keen to reflect on the experiences that have brought us to this point. I would also like to acknowledge the support of the Royal Statistical Society, and the many statistical producers and stakeholders who have inputted their ideas and views about the Code – thank you! Your contributions have challenged our thinking and enriched Code 3.0.
The long and winding road
In October 2023, we kicked off a review of the Code of Practice and asked the question – is it time to refresh the Code of Practice? Following a wide range of engagement activities, by February 2024, the answer was clear: Code 2.1 had served us well – it was solid, trusted and respected. But in the light of the shifting data landscape, technological advancements and mis/disinformation challenges, it was time to think about how the Code could evolve to meet these challenges. So, we prepared a draft Code 3.0 and invited feedback through a formal consultation, which ran from October 2024 to February 2025. And here we are now in November 2025, after further refinement of the draft Code to address the feedback raised with us, with the latest edition.
Ongoing dialogue
Looking back to two years ago, when the Code 3.0 project kicked off, I’m amazed at how far we have come. We have had so many fruitful opportunities to hear from stakeholders across the statistical system and wider communities to inform our thinking. Our understanding about the Code has evolved through our regulatory work and through hearing about others’ experience and perspectives. In fact, some changes we’ve made to the Code are the product of engagement we’ve undertaken since the second edition was published in February 2018.
One example of how our thinking has been shaped by those using the Code is the development of the Code Principles. These largely stem from the work of the ONS sustainable development goal (SDG) team. In 2019 the team needed a way to test non-official data sources for use in monitoring some indicators. Their work led to our development of a set of universal principles which were relevant to any analyst. In turn, Code 3.0 builds on these ideas to unpack TQV in 10 principles which can be applied by any analyst.
Active engagement
Engagement is not a purpose but a means to establish purpose. Active engagement was core to the development of Code 3.0. ‘You said / we did’ is an approach that is often used in response to consultations. We used it ourselves after the Code consultation to summarise what we heard and to give a feel for how we were planning to then act. But as a way of reporting engagement, it misses out the nuance and depth of the exchange of insight.
By focusing on engagement through listening and responding, we have been able to establish an interactive and iterative process rather than a one-off sharing of ideas. We saw feedback not just as a series of edits to be made but as many insightful points to be carefully considered within task and finish groups in OSR.
Open to check and challenge
An important element of establishing any dialogue is the exchange of understanding and respect. Listening is critical for this to occur, as is a degree of empathy. But for the dialogue to be successful, it requires all parties to be open to hearing from each other. Central to that is seeing yourself as accountable for your decisions and actions and being courageous enough to invite criticism as you determine how best to meet your responsibilities.
We have embedded an accountability framework within our Code 3.0 package, which was developed after input from David Caplan, who has been an important stakeholder throughout our Code development. David has worked for 20 years in the GSS, was director of research and analytics at the Audit Commission, and we are happy to hear is the incoming Honorary Officer for Public Statistics at the RSS. At a Code/RSS event, David shared his thinking about an accountability model based on his previous experiences at the Audit Commission. This inspired us to take our framework forward.
Our accountability framework highlights that you must be willing to hear critical feedback: to give an account, be held to account and make good. Accountability relies on you first seeing yourself as accountable to others – it is an attitude. Once you have accepted this frame of mind, you can then find ways to make yourself accountable.
I love the simplicity of the accountability framework, although I recognise that following its principles is perhaps easier said than done. Unless you are willing to hear what others have to say, to reflect on it and then to set out what you are doing in response – whether you can or can’t, agree or disagree – you will be working in a bubble, isolated from hearing about ways you may need to evolve and grow. This kind of approach isn’t something new in OSR – we always aim to work to the standards we demand of others. In fact, thinking about and enhancing our own TQV will feature more prominently in our upcoming new three-year OSR strategy.
Call to action (and listening)
So, as you check out Code 3.0, see how it can focus your thinking on what matters in your own context. Make yourself accountable to your colleagues and stakeholders – invite and listen to feedback, be open to check and challenge, and be frank about your decisions and the information that’s informed them.