Leadership and organisational practices
1.10 Trustworthiness is a product of the people and processes within organisations that enable and support the production of statistics and data. Users told us that they have confidence in NHS England’s statistics and those who produce them, and we found evidence of strong statistical leadership and organisational practices.
1.11 In January 2023, NHS England and NHS Digital merged to create a new, single organisation. Following the merger, there are two Heads of Profession for Statistics/Chief Statisticians at NHS England. They work closely together to oversee the large portfolio of official statistics produced by the organisation and are both active members of the England Health Statistics Leadership Forum. The merger of the two organisations also means that there is now a dedicated statistical governance team (formerly part of NHS Digital) to support the production of official statistics within NHS England.
1.12 NHS England demonstrates good practice in accordance with the orderly release requirements of the Code of Practice. Publication dates for the A&E statistics are pre-announced via the NHS England release calendar and the NHS Digital release calendar. Any revisions to the statistics are carried out in line with published guidance (see the NHS England policy and the NHS Digital policy) and are accompanied by a note on the relevant publication page. One user commented that it is not always clear that revisions have been made to data tables, so NHS England should consider how to make revision notices even more prominent on its outputs.
1.13 Staff involved in the production of the statistics undertake mandatory training on topics such as information governance. They also have access to a range of analytical training, for example on statistical methods, communication and software, and are encouraged to spend time on learning and development. However, a significant challenge for staff is ongoing resource pressures which often impact opportunities for personal development and development of the statistics. It will be helpful to NHS England in addressing the requirements in our report if sufficient resource is made available to the relevant teams.
1.14 We raised some minor issues for improvement which NHS England quickly addressed during the assessment, such as making contact details and latest release dates easier to find. We identified two further requirements in relation to trustworthiness for NHS England to address. These are discussed in the following sections.
Pre-release access to the statistics
1.15 A core principle of the Code of Practice is that statistics should be equally available to all, and not given to some people before others. To preserve this principle, the circulation of statistics in their final form ahead of publication should be restricted, in line with the rules on pre-release access set out in legislation.
1.16 It is good that NHS England publishes pre-release access lists for each of the three statistics releases about A&E activity and that these lists detail the department and job title for those who were granted access. While no pre-release access has been required for the quality indicators release since December 2022, the most recent lists for the monthly and annual A&E releases show pre-release access was granted to more than 80 and 40 people respectively. These appear to be excessively large numbers of people, especially in the context of pre-release access not being required at all for one of the three publications. In addition, both of these lists contain several instances of multiple members of the same team being granted pre-release access.
1.17 We have intervened with other statistics producers in the past where long pre-release access lists have resulted in data leaks. We have subsequently seen the success that producers can have in reducing lists – for example, by improving pre-release discipline (ensuring that those absent, not required or temporarily deployed to other areas at the time of release are removed) and by working closely with colleagues in press and private offices to find an approach that balances the requirements of the Code with the need to brief officials and Ministers to allow them to respond or take action at, or shortly after, the time of publication. It is also our view that multiple members of the same team should not require pre-release access and that team mailboxes should not be used for sharing the statistics.
NHS England should review and reduce its pre-release access lists, bearing in mind the principles of good pre-release practice, to support the principle of equality of access and reduce the risk of data leaks. As part of meeting this requirement, NHSE should share its justification for each requirement with OSR.
Transparency of development plans
1.18 Producers of statistics should be open about plans and priorities for their statistics and about progress towards meeting these plans. Evidence provided directly to us demonstrated that there are clear work programmes in place for producing each of the three statistics releases. Through conversations with the teams, it was also great to hear about the plans and ambitions for future data developments and improvements to the statistics, such as improving the presentation of outputs or using the rich data within the ECDS to produce new and better measures. However, there is very little information about any of these plans in the public domain beyond, for example, some information that was provided in a consultation carried out on the quality indicators and annual A&E publications during Summer 2023. Publishing and maintaining a development plan would make users aware of planned changes to the statistics and allow them to provide feedback on these plans, which may lead to NHS England being able to make further improvements to the statistics.