Ed Humpherson response to Lewis Macdonald MSP: Press Statement from Public Health Scotland on Minimum Unit Pricing for Alcohol

Dear Mr Macdonald 

 Thank you for your letter of 3 July about the use of figures in a press release of 10 June by Public Health Scotland (PHS) concerning the impact of the first year of the Scottish Government’s policy on minimum unit pricing for alcohol. You were concerned that the data used in the press release misdirected subsequent media coverage of the research.  

Having looked at the concerns in detail, we concluded that the main findings of the research (a net decrease in Scotland of between 4 and 5% in sales per adult over the first year of the policy) are dependent on the difference in movements in alcohol offsales in Scotland (a decline in sales of 2.6%) compared with England and Wales (an increase in sales of 2.3%). The researchers have controlled for different effects including using England and Wales as a geographical control. The results of using the geographical control and other controls such as household income gives slightly different results depending on which controls are applied, hence the range of the estimated decline in offsales of between 4 and 5% over the period. The figures in the press release are consistent with these findings.  

The research has effectively reported an estimated change but has not reported the observed year-on-year change. There are areas where there could have been a clearer presentation in the press statement, particularly that the research reports an estimated effect of the policy change. The PHS statisticians we were told had no intention to mislead in the press statement, they were trying to keep the messages straight-forward.  

It would have been helpful in the press statement to refer to the observed year-on-year decline in offsales as was apparently referred to in the Good Morning Scotland radio interview with the PHS investigator that you refer to. Also, there could have been a better explanation about the limitations in the statistics, and PHS might have included some indication of the range of the plausible reductions in offsales (-5.3% to -3.0%). PHS might also have provided some useful lines in the press release to help the media to interpret and quote the figures appropriately. Such explanations protect the integrity of the findings and support users of these numbers in drawing the correct conclusions to inform the decisions they make. 

As you point out PHS is a new agency and through our engagement we have seen that its staff understand the importance of maintaining the standards required of the Code of Practice for Statistics. PHS is building on the strong pedigree of ISD Scotland, one of its component parts, and its statistics officials are working with staff across PHS to instil a culture which looks to draw heavily on the principles of the Code of Practice for Statistics and associated guidance. 

The Office for Statistics Regulation will continue to work with PHS to ensure that support is provided as it develops its practices and will support them in applying the principles of the Code of Practice. 

I am copying this letter to Scott Heald, Head of Profession for Statistics at Public Health Scotland, and Roger Halliday,Chief Statistician and Joint Head of Covid Modelling and Analysis Team at Scottish Government. 

 Yours sincerely 


Ed Humpherson 

Director General  


Related Links

Lewis Macdonald MSP to Ed Humpherson

Lewis Macdonald MSP to Ed Humpherson: Press Statement from Public Health Scotland on Minimum Unit Pricing for Alcohol

Dear Mr Humpherson,

I write to raise concerns about a press release from a new Scottish Government agency, Public Health Scotland, published on 10 June 2020. It was issued with a report containing a statistical analysis of the impact of Minimum Unit Pricing (MUP) on off-sales of alcohol in the first year after the policy was introduced on 1 May 2018.

The news release states that, in the twelve months after the introduction of MUP, off-licence and retail sales of alcohol in Scotland decreased by between 4 and 5% when compared with England and Wales. The news release does not say how the level of such sales changed when compared with off-sales in Scotland itself in the 12 months before MUP was introduced – not even in a footnote. Even more surprisingly, the actual change in levels of sales in Scotland is also omitted from the report published at the same time.

This presentation quite predictably led journalists to report that there had been a fall in off-licence sales in Scotland of between 4 and 5%, thanks to the introduction of MUP. That in turn led other reputable individuals to comment on the story as if there had indeed been such a large fall, because the actual figures were not made available.

The actual figures seem to have emerged only in an interview given by Lucie Giles, Public Health Intelligence Principal at Public Health Scotland, to BBC Radio Scotland’s Good Morning Scotland on the morning of 10 June. She told the interviewer that the actual reduction in off-licence and retail alcohol sales in Scotland was 2.6% during the first year after MUP was introduced, and that there was an increase in sales over the same period in England and Wales of 2.3%.  “Incorporating the figures into a single model, using England and Wales as a geographical control,” she said, “that’s how we have come to those figures of a net reduction of four to five percent.”

There is nothing intrinsically wrong with comparing a 2.6% reduction in Scotland with a 2.3% increase in England and Wales, and suggesting possible explanations for the difference. There may be issues about adding these two numbers together, given that the market for alcohol sales in England and Wales is quite different in scale from the market in Scotland: but a combined figure of this kind could have been presented with the appropriate caveats.

That did not happen. Nobody, as far as I know, other than listeners to Good Morning Scotland at the relevant time on the day of publication, will know how far sales in Scotland actually changed from one year to the next, far less how the published figure of “between 4 and 5%” was reached. Most people are bound to assume that the figure presented actually represents the fall in off-sales in Scotland.

The Glasgow Times for example reported: “According to the report by Public Health Scotland, minimum unit pricing (MUP) could be attributed to a reduction in alcohol consumption per head in Scotland of between four and five per cent overall in the 12 months from May 2018.”

STV, on the other hand, mentioned that the figure was in comparison with England and Wales, but did not make clear what this actually meant. Their story quoted Alison Douglas, chief executive of Alcohol Focus Scotland, who said: “A reduction of between four and five per cent in off-sales in the 12 months following the introduction of MUP is really significant.”

None of the outlets I checked or authorities I saw quoted gave the actual figures for the fall in consumption in Scotland, because that information was not presented to them. It is disappointing that a public agency chose to present statistics in such a misleading way, so that even expert witnesses concluded that the fall in off-sales of alcohol following introduction of MUP was nearly twice as large as it actually was. Given that Public Health Scotland is a new agency, with many important responsibilities, I would encourage you to draw the principles of best practice in the use of statistics to their attention.

I attach below links to the PHS news release, and to the news reporting I have mentioned.

Yours sincerely,


Lewis Macdonald MSP

North East Scotland






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Ed Humpherson response to Lewis Macdonald MSP

The future delivery of social care in Scotland – OSR inquiry submission

Dear Lewis


We have today published our review of Adult Social Care Statistics in Scotland. We are using this work as the basis of our submission to the Health and Sport Committee’s Social Care Inquiry (see annex).

Statistics that support our understanding of people who need or provide care, the impact it has on their lives, how the adult social care sector is currently delivered and how this might need to change in the future are an essential element in an ideal model of care. Without adequate statistics it is also impossible to assess the extent to which social care provision is equitable.

Our submission outlines various issues affecting the quality and value of adult social care statistics in Scotland that need to be addressed. Statistics producers have clearly demonstrated their strong understanding of these issues and share many of the concerns that users raised with us. Work is already underway to bring about positive improvements to adult social care data and statistics in Scotland. However, we believe that a major transformation of adult social care data and statistics is needed to fully meet users’ needs and this will require more fundamental action. We have made recommendations in three strategic areas to support this:

  • clearer responsibility for analytical leadership is required to scope and deliver local and national level improvements
  • the imbalance in resources currently available for health service and social care statistics needs to be addressed
  • data systems need investment to improve the quality of existing datasets and to identify ways to capture new data to fill the many gaps that users have identified.

We will continue to work with a range of organisations to make the case for improvements to social care statistics in Scotland and more widely across the UK. We hope to raise the profile of these issues through this inquiry submission, the more detailed report about Scotland published today, and via our companion reports about adult social care statistics in England and Wales.

I look forward to seeing the conclusions of your inquiry.

Your sincerely

Ed Humpherson
Director General for Regulation

Related links:

Adult Social Care Statistics in Scotland Report (February 2020)

Letter from Ed Humpherson to ISD Scotland, Scottish Government, Scottish Social Services and Care Inspectorate (February 2020)

Letter from Scott Heald, NHS National Services Scotland, to Lewis Macdonald MSP, Scottish Parliament

Dear Mr Macdonald,


Further to my letter of 6th September 2018, I have now concluded my investigation into the data analysis and reporting from the Scottish Intensive Care Society Audit Group (SICSAG) and Information Services Division (ISD), following an anonymous letter outlining a number of concerns.

I have undertaken my review with members of the SICSAG team (including statisticians and clinicians within ISD, and clinicians within SICSAG) and ISD’s Statistical Governance team, which oversees our compliance with the standards set out in the UK Code of Practice for Statistics.

The SICSAG report is not an official statistics publication but is produced, as with all ISD publications, in line with the principles set out in the Code of Practice.  ISD takes its compliance with the Code of Practice seriously and therefore it is important that we investigate the claims made in the letter.  I have also copied this response to the Office for Statistics Regulation, the regulatory arm of the UK Statistics Authority, so that they can undertaken an independent review.

It is disappointing that the letter sent to me is anonymous as my preference would be to discuss the issues raised with the complainants directly.  Previous experience with other issues has shown that open dialogue between all parties can help build trust and understand the crux of the issues raised and prevent misunderstandings which can happen through written correspondence alone.  As noted in the letter to me, the complainants sent a similar anonymous letter to ISD and SICSAG last year.  ISD and SICSAG undertook a review at that time but due to the anonymous nature of the letter, it was not possible to respond directly last year.

Responding to this year’s letter via the Health & Sport Committee allows us the opportunity to address the points raised by the complainant.  That said, my preference would still be for a face to face meeting with all parties to further explore any ongoing issues.

The investigation included a review of all data analysed and reported in the letter, particularly relating to Aberdeen Royal Infirmary (which the complainant has highlighted as an area of concern), a review of the analysis methodology used by SICSAG, a review of current SICSAG governance guidelines and a review of past annual reports commentary.   The results of the investigation are given in the appendix attached to this letter.  I have grouped the response around key themes raised by the complainant but please let me know if there are any areas which you feel have not been addressed or require additional clarity.  The response in relation to the statistical analysis undertaken is technical in nature and this will allow the separate review by the Office for Statistics Regulation to understand ISD’s approach and our reasons for adopting this methodology and our subsequent reporting of the results.

I would like to take this opportunity to thank the complainants for their letter.  They are clearly passionate about this topic and it is important that their concerns are addressed and acknowledged.  ISD always welcome feedback as this provides us with valuable insight into our services and assists us with improving our outputs, and in the case of our audits, inform service improvement and therefore improvements to services for patients.

Please let me know if you have any further questions or comments. I would very much welcome the opportunity for all parties involved to discuss this with you and, if they were willing, the complainants.

Yours sincerely,

Scott Heald


Related Links:

Ed Humpherson to Lewis Macdonald MSP