Rob Kent-Smith to Peter Schofield: Increase in the number of people on Universal Credit

Dear Sir Peter

We have received a number of complaints relating to a press release published by the Department for Work and Pensions (DWP) on 13 March entitled ‘Almost two million people on Universal Credit not supported to look for work’.

The original version of the press release stated that: “The number [of people on Universal Credit health with no requirement to look for work] has almost quadrupled since the start of the pandemic when 360,000 people were considered too sick to look for work – a 383% rise in less than five years.”

The statement that the number of people claiming disability elements of Universal Credit has increased by 383% presents an entirely misleading picture to the public. The figure does not recognise that the majority of this increase is due to the process of migrating people from legacy benefits, such as Employment and Support Allowance, to Universal Credit over the last few years. When these people are accounted for, the actual increase in the number of people claiming disability elements of Universal Credit is 50%.  

After we raised concerns with DWP, the press release was amended on 27th March. The updated version of the press release includes some references to people moving from other benefits and acknowledges that the number of people with no requirement to look for work across Universal Credit health and other benefits since the pandemic has increased by 50%.

However, we consider that these additions do not go far enough. The press release still places considerable emphasis on the misleading 383% figure and does not provide the necessary context in a way that members of the general public would understand. We also note that the press release does not state that it is been updated which we would encourage as a matter of transparency.

It is vital that statisticians are included in the drafting process for communications using official statistics, including press releases, to ensure that such an issue is not repeated in the future. As the Head of Profession for Statistics, Steve Ellerd-Elliott (copied), should be supported by the department in upholding his responsibility to ensure statistics are used appropriately.

We request that the press release is updated by Friday 4th April to remove reference to the 383% figure and that this figure is not used going forward.

Rob Kent-Smith

Deputy Head of the Office for Statistics Regulation

Ed Humpherson to Abbie Self: Review of the quality of criminal court statistics for England and Wales

Dear Abbie

We have now completed our review of the quality of the Ministry of Justice’s (MoJ) criminal court statistics for England and Wales. I am grateful for the positive contribution and engagement from your team in MoJ and your colleagues in HM Courts and Tribunals Service (HMCTS) throughout the review.

We undertook our review because of concerns about inaccuracies in the Crown Court data. Having examined the statistics in depth, we are confident in the quality of the criminal court statistics and are satisfied that you have provided sufficient assurances to users about the quality of the Crown Court data. We judge that the statistics can retain their accredited official statistics status.

We commend MoJ and HMCTS on the collaborative approach to investigating and addressing the Crown Court data quality issues. There is now a better shared understanding of the data and case management systems and stronger working relationships between MoJ and HMCTS. It is also welcome that you have aligned the methodologies used to produce the official statistics and HMCTS’s management information, which has enhanced the coherence of Crown Court data.

We identified two recommendations that you should address to enhance the quality of the statistics. These are expanding and routinely reviewing the quality information published alongside the statistics; and adding caveats and explanations of uncertainty to the statistical bulletin. You have committed to implementing these in the June 2025 statistics release. We will continue to engage with you and your team as you make improvements.

I am copying this letter to Antonia Romeo, Permanent Secretary; Ross Gribbin, Director General for Policy, Analysis and Legal Group; Hugh Stickland, Chief Data Officer and Chief Scientific Adviser; and Damon Wingfield, Deputy Director for Courts and People Statistics and Analysis.

Yours sincerely

Ed Humpherson
Director General for Regulation

Related links: Ed Humpherson to Abbie Self: Review of MoJ’s criminal court statistics

Review of the quality of criminal court statistics for England and Wales

Ed Humpherson to Mike Keoghan: Alternative Release Times for Economic Statistics

Dear Mike,

Thank you for sharing with us your assessment of your practice of releasing market-sensitive economic data outside of market trading hours at 0700, rather than the default release time for official statistics of 0930.

Under our Alternative Release Times (ART) policy it falls to the producer, in this case ONS, to periodically consider the need and public good case to continue with alternative release times. We requested that ONS carry out this review as our call for evidence as part of our Code Review attracted nine responses, who made the case for return to an 09:30 publication time. Given release times was not the primary focus on the consultation, the evidence was partial. Therefore, we asked ONS to assess the issue in a way that takes account of the full range of impacts, including public benefits. We also asked that this assessment be based on effective engagement with stakeholders.

Your assessment recommends continuing to release market-sensitive data at 0700. This is on the basis that it increases the visibility of key statistics for the public via the media, and so better serves the public good. Additionally, this mitigates the risk that ONS’s website is not robust enough to manage the increased traffic that reverting to 0930 would likely lead to, which could risk orderly access to data for users. You note that ONS intends to reconsider this issue when it is assured that its new website and API are robust enough to manage the increased traffic and this has been demonstrated for a year. ONS is also committed to ensuring that this future review is not restricted to a binary choice of 0700 or 0930 but should look at all options, including times between these options.

We have considered our response to your assessment from the following perspectives:

  • the importance of maintaining orderly release given the risks around the performance of the ONS website;
  • the role of enhanced media coverage in making statistics more available and accessible, in turn serving the public good;
  • the differing stakeholder views, and
  • the impact on the functioning of the SONIA market.

We support your plans to continue releasing these market sensitive statistics at the alternative time of 0700 instead of 0930 for the moment. We recognise the value of increased visibility of key statistics and are keen to maintain the orderly release of these vital statistics. We note your approach to maintain these alternative release times until ONS is assured that its new website and API are robust enough to manage the increased traffic that moving from 0700 could lead to. At that point ONS should reconsider its approach, including whether there is an alternative option, which better meets the needs to users.

You may be aware that we periodically review ARTs to make sure they are still justified and warranted. To help us consider this one, we would welcome an update from ONS on its future review of an alternative release time for market sensitive economic statistics by 31 December 2025. If you think this date will cause you any problems, please let me know.

Please ensure the time of release, the reasons for using an alternative release time, and your plans for reviewing this, are clearly and widely communicated with users and other stakeholders with an interest in these statistics.

Yours sincerely,

Ed Humpherson
Director General for OSR

Related links: Ed Humpherson to Mike Keoghan: Alternative Release Time for Economic Statistics – Office for Statistics Regulation 

Alternative release times requested under the Code of Practice for Statistics – Office for Statistics Regulation 

Ed Humpherson to Alastair McAlpine: Scottish Health and Wellbeing Census

Dear Alastair,

Thank you for your response to our letter regarding the Health and Wellbeing Census in Scotland. We welcome the publication of the Health and Wellbeing Census Scotland: Background Report. We consider that this document will provide valuable information to users and meets the requirement for Scottish Government to review its approach to developing questions for the Health and Wellbeing Census as set out in our July 2022 letter.

We appreciate your assurances relating to your role as Chief Statistician for Scotland and Scottish Ministers. We look forward to seeing how the recommendations on decision making with respect to cross-cutting statistical projects, as outlined in your internal review on Scotland’s Census 2022, are taken forward.

Yours sincerely

Ed Humpherson
Director General for OSR

Related links: Alastair McAlpine to Ed Humpherson: Health and Wellbeing Census – Office for Statistics Regulation

Ed Humpherson to Alastair McAlpine: Scottish Health and Wellbeing Census – Office for Statistics Regulation 

Ed Humpherson to Alastair McAlpine: Health and Wellbeing Census in Scotland – Office for Statistics Regulation 

Siobhan Tuohy-Smith to Alex Lambert & Liz McKeown: ONS’s transformation of the Labour Force Survey (TLFS)

Dear Alex, Liz

Since our letter in July 2023, we have continued to review ONS’s transformation of the Labour Force Survey (LFS) against the Code of Practice for Statistics, alongside our review of LFS-derived Labour Market Statistics following the accreditation suspension last year. We have today published a progress report which consolidates our work on both the LFS and TLFS, bringing together our judgements to date and providing updates on the remaining open recommendations and requirements.

On the TLFS, we have found that ONS is engaging well with users, and that the scope of this engagement has been widening. ONS has also been increasingly open with its communication. However, users remain frustrated about the lack of clarity about when the transition to the TLFS will be made. We have found that our previous recommendations about the TLFS remain relevant. We have also made two additional recommendations calling on ONS to publish more detail about the plans to transition to the TLFS, and to set out its plans for regular reporting on the progress of its interim action plan from its ‘lessons learnt’ exercise. For the LFS-derived estimates, we have found that ONS has acted to address most of our requirements. We recognise that given the five-wave design of the LFS any changes take time to feed through and that ONS expects changes to be fully included through all five of the survey waves in the May 2025 publication. We will engage with your team and users to understand the extent to which these changes have increased quality sufficiently to meet user needs. In this context, the classification official statistics in development continues to be appropriate.

We also support ONS’s plans to publish a series of articles by June 2025 exploring the coherence between estimates from the LFS, estimates from business surveys and estimates from administrative data as this will support user need during this period of transition.

I would like to thank your teams for their continued positive engagement with us on these reviews and we will continue to challenge and support the teams, reviewing progress against each of the deadlines outlined in today’s report.

Please do not hesitate to get in touch if you would like to discuss any aspects of this letter and accompanying progress report.

I am copying this letter to Rachel Skentelbery, Deputy Head of Profession for Statistics at ONS.

Yours sincerely

Siobhan Tuohy-Smith

Assessment Programme Lead

Siobhan Tuohy-Smith: OSR review of salmon statistics

To:

Stuart Homann, Environment Agency 

Simon Toms, Environment Agency 

Steven King, Natural Resources Wales 

Ben Wilson, Natural Resources Wales 

David Maxwell, Centre for Environment, Fisheries and Aquaculture Science 

Alan Walker, Centre for Environment, Fisheries and Aquaculture Science 

 

Dear all,

We have recently been in touch with you and your colleagues involved in producing the Assessment of Salmon Stocks and Fisheries in England and Wales statistics. This publication is jointly produced by the Environment Agency (EA), Natural Resources Wales (NRW) and the Centre for Environment, Fisheries and Aquaculture Science (Cefas). Given the proposed changes to methods and reporting for these statistics, we have agreed to carry out a short review to offer advice, support and recommendations to help you manage these changes in line with the Code of Practice for Statistics.

We expect the review to broadly cover:

  • Changes to methods: How users and stakeholders have been informed of the proposed changes to methods; assured that the proposed methods are sound and provide the best available estimates; told about any impact on the statistics; and given the opportunity to feed in to decision making.
  • Changes to reporting: How users and stakeholders have been considered in the proposed changes to reporting; informed about the changes and how their needs will continue to be met; and how outputs will be accessible and continue to provide clarity and insight that serve the public good.
  • Institutional governance and statistical leadership: The review will consider aspects of decision-making, transparent processes and the orderly release of statistics. We will focus on salmon statistics, but any recommendations are likely to apply at an organisation level.

If we find that advice or recommendations on areas outside this scope would be helpful to ensure the statistics serve the public good, we will include these in the review.

I look forward to working with you and your teams.

I am copying this letter to Ian Lonsdale, Head of Profession for Statistics, Defra.

Yours sincerely

Siobhan Tuohy-Smith

Assessment Programme Lead

 

SEEN in Health Chairs to OSR: Request to declassify NHS staff survey data

Dear Mr Humpherson,

We are grateful to the Office for Statistics Regulation (OSR) for their thorough consideration of the issues we raised regarding the NHS 2024 staff survey, a summary of which can be seen on our website.

We value the OSR’s recommendation that clearer guidance and definitions are provided in future surveys, and crucially, welcome the commitment by NHS England to improve their data collection standards. We note that the data collected in the staff survey is not officially accredited, so no accreditation can be removed, but hope the OSR’s continued engagement with NHS England will help ensure lessons are swiftly learned. Whilst the 2024 staff survey cannot be amended, the internal NHS England 2025 staff survey is due to launch imminently. Immediate steps can, and should, therefore be taken to review and alter questions which undermine the clarity, accuracy and quality of data being sought.

The NHS has 1.5 million staff and is the biggest employer in Europe. There is a level of rigour that patients and staff alike can expect to be applied when a workforce survey is undertaken in an organisation of this scale, yet inaccurate data collection leaves the NHS unable to monitor protected characteristics accurately to prevent discrimination. We will continue to raise concerns where the distinct concepts of sex and gender identity are used interchangeably or wrongly conflated, recognising this occurs to the detriment of staff, patients and the credibility of the organisation as a whole. We note 2 the OSR’s recommendation that concerns regarding compliance with the Public Sector Equality Duty (PSED) are raised directly with the Equality and Human Rights Commission (EHRC). This will be actioned as a matter of priority.

As a staff network, our preference is always to engage proactively and positively to support our colleagues, leaders and associated stakeholders in their respective efforts to ensure the NHS is a safe, lawful workplace. The concerns SEEN in Health have raised here are not limited to England, and we would encourage staff across the devolved nations to highlight similar problems where apparent in the Scottish, Welsh and Northern Irish workforce surveys, with reference to the OSR’s letter in survey responses where helpful.

We look forward to NHS England implementing the necessary changes to meet its obligations under equality legislation, and ensuring, at a minimum, accuracy in data collection.

Kind regards,

SEEN in Health Chairs

 

Letter From SEEN in Health Chairs to Ed Humpherson

Letter From Ed Humpherson to SEEN in Health Chairs 

Ed Humpherson to Alastair McAlpine: Scottish Health and Wellbeing Census

Dear Alastair

In July 2022, we wrote to you following our compliance check of the Scottish Health and Wellbeing Census in July 2022. In this letter, we requested that the Scottish Government review its approach to developing questions for the Health and Wellbeing Census and that the outcomes of this review be made publicly available.

To date, some 30 months later, the outcomes of this review have still not been made public. The publication of this information is key to providing users with important methodological information that will support transparency and trust in the Scottish Government. We request that the Scottish Government publish the outcomes of this review within the next 30 days. If this deadline is not met, we will take steps to escalate this issue to a ministerial level.

I also consider that there is a broader question surrounding your role as the Chief Statistician for Scotland. The Code of Practice for Statistics sets a requirement for ‘independent decision making and leadership’ on statistical matters like the ones at issue in this case. I would welcome a response from you that provides assurance on the processes and governance within the Scottish Government that allow you to carry out this role effectively.

Yours sincerely

Ed Humpherson
Director General for OSR

Related links

Ed Humpherson to Alastair McAlpine: Health and Wellbeing Census in Scotland – Office for Statistics Regulation 

Ed Humpherson to Sandy Fitzpatrick, Director of Census and Social Statistics, Northern Ireland Statistics and Research Agency: 2021 Census in Northern Ireland, phase 3 report

Dear Sandy

Assessment of the 2021 Census in Northern Ireland

Today we have published our phase 3 assessment report of the 2021 Census in Northern Ireland. This report, our third and final report, focused on assessing how well NISRA’s census outputs have met users’ needs and revisited the requirements outlined in our phase 2 report in 2021. We can confirm that the 2021 Census statistics in Northern Ireland are produced in compliance with the Code of Practice for Official Statistics, meaning that these official statistics meet the highest standards of trustworthiness, quality and public value.

NISRA has been dedicated to delivering high quality and accessible census outputs which have met the needs of a wide range of users in line with the standards of the Code of Practice for Statistics. My team and I were impressed with the high level of satisfaction reported to us by users of the census statistics. NISRA’s innovative approach to the outputs, particularly the development of a new dissemination tool, the Flexible Table Builder, which allows the creation of bespoke tables, has been particularly valuable in enabling users to maximise their use of the results and provides an example of good practice for other producers to follow.

In addition, NISRA responded well to the requirements outlined in our phase 2 report. NISRA’s comprehensive approach to addressing the requirements included effective user and public engagement, the provision of sufficient documentation on quality and methods, and the publication of timely, accessible and flexible census outputs. This impressive response was achieved despite the challenge of delivering Census 2021 during the COVID-19 pandemic. These findings reinforce our designation of the 2021 Census in Northern Ireland as accredited official statistics.

To inform future population work, our assessment report includes five recommendations for NISRA to address. Of note, we recommend that NISRA can do more to support the appropriate use of data affected by the pandemic. We also want to see NISRA continuing to work with other producers to improve the comparability of census statistics across jurisdictions. We look forward to seeing how you address these findings in line with NISRA’s commitment to learning and improvement outlined in the Census 2021 general report.

I would like to thank your team for their positive contribution and engagement throughout the assessment process. If you would like to discuss any aspects of this letter or the accompanying assessment report, please get in touch.

Yours sincerely

Ed Humpherson
Director General for OSR

Related Links:

Phase 1 – preliminary findings of the Censuses across the UK

Phase 2 – Assessment findings: 2021 Census in Northern Ireland

Phase 3 – Assessment of compliance with the Code of Practice for Statistics: 2021 Census in Northern Ireland

Ed Humpherson to David Marshall (NISRA): Confirmation of National Statistics designation for 2021 Census in Northern Ireland

David Marshall to Ed Humpherson: Northern Ireland Census assessment

Ed Humpherson to Peter Benton and David Marshall: Assessment of 2021 Census in England and Wales and 2021 Census in Northern Ireland

Siobhan Tuohy Smith to Elaine Drennan: Compliance review of disability payment statistics produced by Social Security Scotland

Dear Elaine  

We recently completed a compliance check of Social Security Scotland’s Adult Disability Payment and Child Disability Payment statistics, which are both published as official statistics in development. To support their further development, we have carried out a high-level investigation into whether the statistics are being improved in line with the Code of Practice for Statistics. In this letter, we outline our findings and improvements to consider as your team continues its work on these statistics. 

These statistics show information on applications and payments for child and adult disability payments. The main messages from the statistics are clearly explained, with appropriate commentary. Suitable charts and tables are used to illustrate the statistics. We judge that the statistics are presented impartially and have been released in an orderly manner, in line with the Scottish Government’s statistics publication timetable. To inform users of any changes to past data, the outputs include a description of the revisions made. 

Suitable data sources are used to compile the statistics, and the team is planning to further improve how it explains the limitations of the data. The statistics are sourced from the person-level dataset held in Social Security Scotland’s own internal case management system. The data are extracted and securely transferred to the statistics team. There is some information published on the limitations arising from the methods used to compile the statistics, including bias and uncertainty. The statistics team told OSR that it is planning to publish more information about uncertainty in the data, potential biases and the resulting impact on the statistics, which is good practice. 

Currently, part of the data processing is manual, and the statistics team told OSR that it is in the middle of transferring to an automated statistics production pipeline. The plans to automate the data processing process are in line with good practice and should improve the quality of the statistics. Once the transition to automation is complete, Social Security Scotland should publish detailed information about the new quality assurance steps and stages. It should also consider publishing the software code used to produce the statistics. 

Engaging with users to understand their needs will enable Social Security Scotland to consider and prioritise developments in line with user need. The statistics team indicated that it is engaging with a range of users in central government, local government and the NHS. We also welcome the fact that users approach the statistics team in an ad hoc way and that the team asks for feedback to gather insight on how to develop the statistics. 

To further enhance the Trustworthiness, Quality and Value of these statistics, we have identified the following improvements for your team to consider: 

  • To provide users with a wider view of the disability benefits landscape, Social Security Scotland should consider providing information about other UK disability payments statistics in the release and commenting on how the statistics should or should not be compared. 
  • Publishing more detail about the quality assurance processes would provide greater assurance to users. For example, Social Security Scotland should include a process map, identify potential sources of bias and error, and describe the actions taken to minimise risks to data quality. 
  • It would help potential new users if Social Security Scotland published more information about its statistics user engagement plans, so that users know that it are willing to hear their views. 
  • To support the development of these statistics, and in line with our guidance about official statistics in development, Social Security Scotland should consider publishing more detail about its plans to develop these statistics, including timelines and how users will be involved the process. 

I would like to thank your team for its positive engagement with us during this review. We will continue to engage with you as you develop these statistics. Once you consider that these statistics, or other statistics in your portfolio, are ready for a full assessment against the Code, please do not hesitate to get in touch. 

I am copying this letter to Alastair McAlpine, Chief Statistician of the Scottish Government. 

 

Yours sincerely 

Siobhan Tuohy-Smith 

Assessment Programme Lead

Related Links:

Letter: Ed Humpherson to David Wallace: Transparency and user engagement in the production of official statistics