Dear Emma

Regulatory guidance on collecting and reporting data about sex and gender identity in official statistics

I am writing to you in your capacity as the Deputy National Statistician with oversight of the Government Statistics Service (GSS). The GSS plays a crucial role in the statistical system, which includes providing information to statistics producers on harmonised standards for data collection.

Today we published new guidance to support official statistics producers in applying the principles of the Code of Practice for Statistics when making decisions about the collection and reporting of statistics and data about sex and gender identity. This guidance updates and supersedes the previous OSR draft guidance published in 2021.

Our key message in the guidance is that official statistics producers should have a strong understanding of their own data collections and of how these meet the needs of their users, they are clear about what information they are collecting and why, and that they explain this information as straightforwardly as possible both to respondents and data users.

I have today also written to the Chief Statisticians of Scotland, Wales and Northern Ireland and emailed all Heads of Profession for statistics setting out my expectation that they use and promote the guidance within their respective areas of oversight. I ask that, with them, you lead on promoting the OSR guidance to all official statistics producers across the GSS.

As Deputy National Statistician you play a key role in initiating and leading work on these topics across the GSS. To develop this guidance we engaged with a wide range of statistics producers across the UK. I would like to take this opportunity to share the views that are relevant to the work of the GSS.

Statistics producers told us they would like there to be more support available when working with or making decisions on data and statistics about sex and gender identity. This was particularly the case for producers who shared that they did not have much experience or knowledge of the topic area. We also heard concerns that there may not be sufficient support in place to ensure Heads of Profession are able to consistently deliver the responsibilities set out in the guidance. Lastly, the absence of standard definitions and questions, and the lack of a published timeline by the GSS for the development of these, were raised as issues by many of the statistics producers we talked to.

We are aware that the GSS Harmonisation team’s work plan on sex and gender identity is currently paused. We recommend that, in restarting this work, consideration is given to the following short and medium term recommendations:

Short term recommendations

• The GSS should identify where there is expertise on sex and on gender identity data across the UK statistics system and connect statistics producers who want to access more support with this expertise.
• The GSS should use its convening role to support Heads of Profession and other government statisticians to continue to identify and share best practice in both survey and operational administrative settings. We recommend that this is done in collaboration with the Chief Statisticians of Wales, Scotland and Northern Ireland.
• As part of this short term work, information on any GSS activities, including timescales for any planned work, should be kept up to date and be easily accessible to statistics producers and wider stakeholders.

Medium term recommendation

• Following publication of the Cabinet Office and the Department for Science, Innovation and Technology review into sex and gender data, the GSS should consider what further steps may be necessary to put into operation GSS harmonised definitions of key terms and common standards for the collection of data. This work should build on our guidance and evaluate the effectiveness of the approach taken.

I would be happy to meet with your team to talk through these points in more detail if this would be helpful.

Yours sincerely

Ed Humpherson