UK Statistical System UK Statistics Authority Code of Practice
Casework

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

 

Jen Woolford to Ed Humpherson: Review of the quality of police recorded crime statistics for England and Wales

Dear Ed,

Today we published our action plan for improving the quality of police recorded crime statistics in England and Wales. This was developed in response to the Office for Statistics Regulation (OSR) review of the quality of police recorded crime statistics for England and Wales.

I would like to thank your team for its positive engagement and support throughout the review. While the OSR report recognised the significant progress that has been made in improving crime recording, it also outlined recommendations for us to support further improvements to data quality. We have worked with the Home Office and His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services (HMICFRS) to produce an action plan for addressing these recommendations.

The action plan outlines how we will address the key areas that OSR identified for improvement. These include strengthening oversight of police force data quality, better communication of the quality of the statistics, data quality improvement initiatives and greater collaboration and knowledge sharing between the organisations involved in collecting and processing police recorded crime data.

Within the action plan, we have prioritised actions into improvements by summer 2025 and those that are longer term. As we progress through this action plan, we will continue to update and provide evidence to our users.

We look forward to continuing to work with you and your team as we implement these improvements.

Yours sincerely,

Jen Woolford

Director of Public Policy Analysis, Office for National Statistics

Letter from Alex Lambert & Jen Woolford to Ed Humpherson: Review of household total wealth in Great Britain

Dear Ed,

We are writing in response to your letter setting out your intention to review Household total wealth in Great Britain – the latest statistics from the Wealth and Assets Survey (WAS) – for compliance with key elements of the Code of Practice for Statistics.

WAS is an important and unique source of data on wealth in Great Britain and we welcome the opportunity to engage with you and your team on the quality of the survey data and corresponding statistics.

As requested, we are happy to share additional quality assurance material to support your review. We will also share our progress and plans to address survey collection challenges impacting the quality of these wealth statistics. They form part of our wider programme of improvements to increase the quality of household surveys which has already increased response on the Labour Force Survey and Living Costs and Food Survey.

Yours sincerely

Alex Lambert, Director of Social Surveys

Jen Woolford, Director of Public Policy Analysis

Ed Humpherson to Alex Lambert and Jen Woolford: Review of Household total wealth in Great Britain

SEEN in Health Chairs to OSR: Request to Declassify NHS Staff Survey Data

Dear OSR

We are writing to you as the Chairs of the Sex Equality and Equity Network for NHS employees (SEEN in Health) which launched on 11th May 2024.

Our mission is to create an environment in the NHS where staff are encouraged to raise issues related to the protected characteristic of sex and feel safe doing so – speaking up for themselves as employees and on behalf of patients. This is critical both to their rights and wellbeing as employees of the NHS, and as a workforce dedicated to delivering high quality and safe care in the NHS. We aim to ensure that workplace-based policies and training resources are compliant regarding the protected characteristic of sex, and reflect the responsibilities of NHS organisations under both the Equality Act (EA10) and Public Sector Equality Duty (PSED).

We have been inundated with concerns from NHS employees in relation to the staff survey (https://www.nhsstaffsurveys.com/survey-documents/). As the biggest employer in Europe this survey should be a rich source of data but its questions demonstrate bias, contrary to the PSED, and will prevent NHS employers from both understanding and protecting staff from discrimination. Many staff are boycotting the survey as a result.  Some examples are listed below:

  • Question 15, “Does your organisation act fairly with regard to career progression/promotion, regardless of ethnic background, gender, religion, sexual orientation, disability or age?”, fails to ask the respondent if their employer acts fairly in respect of all protected characteristics. Despite the introduction of the Worker Protection (Amendment of Equality Act 2010) Act 2023 and previous staff surveys indicating high rates of sexual harassment of women (which is likely to be under-reported due to the perennial issue of flawed questioning on sex), this question does not ask if their employer acts fairly regardless of their sex. It also fails to account for whether staff who may need protection under the protected characteristic of gender reassignment or belief are being treated fairly by the NHS.
  • Question 16 fails to ask the respondent if they have experienced sex discrimination, despite the NHS introducing the Sexual Safety in Healthcare charter this year. As with the previous question ‘gender’ has no legal basis and the NHS cannot assume that all respondents will understand that gender, in this instance, presumably refers to sex.
  • Question 17 asks respondents about their experiences of unwanted behaviour of a sexual nature. It is unclear how, given the phrasing of question 16 and the errors [options] in question 27 analysts will be unable to determine progress made to reduce sexual harassment towards women.
  • Question 27 a & b ask for information on gender that best describes them. Analysts will not be able to determine with any degree of accuracy, the sex of respondents due to the conflation of the terms sex and gender. The survey also compels, by way of not including an option to state ‘do not have a gender identity’ in 27a, respondents to acknowledge a belief they may not have. We understand this alone has deterred many staff from completing the survey, leading to result bias.

NHS data is used to inform internal activity, from recruitment and communications to staff network endorsement and policy. For example, NHS Confederation’s Health and Care LGBTQ+ Leaders Network use data on gender, not sex, to leverage favourable policies, claiming that ‘LGBTQ+ staff represent one in 20 of the NHS workforce…persistent inequity in staff experience…LGBTQ+ Leaders Network conducted its largest ever survey…to delve deeper…to better understand the trends…’. Please refer to https://www.nhsconfed.org/publications/illusion-inclusion-lgbtq-staff-experience-healthcare. Trends cannot be identified from flawed data: gender cannot be assumed a like-for-like replacement for sex, and survey respondents are most likely to exclude those who recognise sex as binary as a result.

We believe the survey contravenes the Code of Practice for Statistics and would propose that NHS staff data relating to sex, discrimination, unwanted behaviour of a sexual nature, gender and sexual orientation are declassified until such a point that the NHS uses clear, sexed language.

We appreciate your consideration of these issues and look forward to your response.

Kind regards

SEEN in Health Chairs

Letter From Ed Humpherson to SEEN in Health Chairs 

Ed Humpherson to SEEN in Health Chairs: Request to Declassify NHS Staff Survey Data

Dear Chairs,

Thank you for your letter outlining your concerns regarding the NHS staff survey in relation to the use of the term ‘gender’ in certain questions.

As the regulator for official statistics, our role is to ensure that official statistics are produced in accordance with the principles of trustworthiness, quality, and value as outlined Code of Practice for Statistics. We also have additional guidance for statistical producers on Collecting and reporting data about sex and gender identity in official statistics. We have considered your concerns against both the Code of Practice and our guidance for statistical producers.

You raised some concerns relating to compliance with the Public Sector Equality Duty (PSED). As set out in our guidance, it is not within OSR’s remit to determine the requirements of relevant legislation or whether they are being adhered to and so we have not directly responded to these concerns. If you would like to take these concerns forward, we recommend that you raise them directly with the Equality and Human Rights Commission.

You raised concerns about the conflation of the terms ‘sex’ and ‘gender’. We agree that there is scope for NHS England to be clearer about which concept the survey is aiming to collect and that a lack of clarity could result in the distinct concepts of sex and gender identity being conflated. Our guidance sets out that “producers should clearly explain why certain information is or is not being collected and be transparent and open about their decision-making processes and the evidence and priorities used to inform their choices”. In addition, “It is the responsibility of statistics producers to decide on and explain the definitions used within any data collections and statistical outputs.” We consider that NHS England should look to provide clearer guidance and definitions to both survey respondents and data users in future surveys.

In response to these concerns being raised, NHS England have agreed to the review the terminology used for the 2025 questionnaire. This review will take account of our guidance, the recently updated Gender Identity Data Harmonisation Guidance produced by the Government Statistical Service, and any potential forthcoming legislative changes. As the 2024 questionnaire has already been issued with results due out later in the year, the 2025 survey offers the first opportunity for NHS England to implement any necessary changes and so we welcome this commitment.

In the interim, NHS England have taken steps to insert a paragraph in the Technical Guidance to acknowledge that this is a complex and evolving area which may require changes in the future. We will continue to engage with NHS England with a view to providing support on this issue.

You requested that “NHS staff data relating to sex, discrimination, unwanted behaviour of a sexual nature, gender and sexual orientation are declassified”. As these statistics are currently classified as official statistics and not accredited official statistics, it is not possible for the accreditation to be removed.

Thank you again for raising this issue with us. We will continue to engage with NHS England to ensure that any relevant questions concerning this topic align with our guidance.

Yours sincerely

Ed Humpherson Director General for Regulation

Letter From SEEN in Health Chairs to Ed Humpherson