2024/25 casework themes
Supporting government to use statistics appropriately
Our 2023/24 casework report reflects on OSR’s role during the 2024 UK General Election. While the election period saw an increase in the amount of casework being handled by OSR, the immediate post-election period (August and September 2024) saw 18 cases raised with us, a decrease from 25 during the same period in 2023. This comparably quiet period was most pronounced in the month of August 2024, when we only had one new case raised with us. By October 2024, the introductory period for the new government had passed, which saw public and parliamentary casework enquires to OSR return a level similar to that seen under the previous government in 2023/24.
The outcome of the 2024 General Election resulted in a large intake of new MPs as well as new ministerial teams being formed to lead the work of the UK Government. This change provided OSR with an opportunity to reinforce our that the appropriate use of statistics is not only the responsibility of statisticians, but everyone within government. Our investigations and responses to issues raised in casework often require engagement with ministers, civil servants and others who sit outside the statistical profession. This can include policy and communications teams within government departments and special advisers.
The new government’s missions and the Plan for Change provide a powerful user need for data and statistics, and it is positive that the government wants to use data to communicate its policy initiatives to the public. This can, however, sometimes come at the expense of the implementation of our expectations around intelligent transparency. An example of our work in this area was OSR’s response to casework raised with us about comments made by the Prime Minister, Sir Keir Starmer, at the 2024 Labour Party Conference regarding immigration returns (see the case study below). Our intervention ensured that unpublished data referred to by the Prime Minister were subsequently put into the public domain to aid transparency and enable scrutiny.
The principle of equal access means that all statements involving statistics or data must be based on publicly available data, preferably the latest available official statistics where possible. Claims should not be made based on data to which ministers have privileged access, as this prevents the claims from being scrutinised and undermines confidence in official statistics.
Case study – Prime Minister’s comments on immigration returns
On 24 September 2024, Sir Keir Starmer made a statement at the Labour Party Conference which included the claim that there had been “a 23 per cent increase in returns of people who have no right to be here, compared with last summer”. A request was made for OSR to review this claim through our casework function.
Our investigation found that, at the time the Prime Minister made this claim, there were no Home Office data or statistics available in the public domain for the relevant time period to support the statement. After we engaged with the Home Office and officials in Number 10, the Home Office published an ad hoc statistical release to provide the public with the statistics which had been the basis of the Prime Minister’s conference statement. We welcome this illustration of intelligent transparency in practice, with the government taking prompt action to provide the public with clear and timely statistics in an area of high public interest.
Whilst we did not write publicly to the Prime Minister in this instance, our Director General wrote a blog about this case in October 2024.
An important source of new casework continues to come from elected officials, both at Westminster and in the devolved legislatures. In the 2024/25 period, we received a total of 16 new casework enquiries from legislators and elected officials across the UK, continuing the level seen in the previous two years (17 cases in 2023 and 16 cases in 2024). Of these, six were from members of the Scottish Parliament and one from a member of the House of Lords. OSR received no casework enquiries from members of the Senedd over the last year.
The enquiries raised by elected officials can range from cases relating to speeches in Parliament to press releases and policy documents, or, as in the case study below, ministerial statements reported by the media. The example below concerns a query raised with us by an MP regarding a statement by a Ministry of Justice minister regarding working-age adults with criminal convictions. It demonstrates the value of OSR’s role in supporting government to use statistics appropriately through engaging with government ministers and elected representatives – in this case, regarding the use of language.
Case study – Working-age adults with criminal convictions
In early 2025, Kieran Mullan MP wrote to us regarding statements by Lord Timpson OBE, Minister of State for Prisons, Probation and Reducing Reoffending, on the proportion of the population with a criminal record and on an article published by The Times on 9 January 2025 where the terms “criminal record” and “criminal conviction” are used seemingly interchangeably.
We responded to Mr Mullan, setting out that using these terms interchangeably is imprecise – a criminal record is not the same as a criminal conviction. We contacted Lord Timpson’s ministerial office directly to let them know our findings; Lord Timpson replied to acknowledge the importance of referring to figures accurately.
Our intervention’s core message was to emphasise that when using figures publicly, it is important that they are quoted accurately to best support public understanding on the given issue.
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Protecting statistical independence
A fundamental principle of the Code of Practice for Statistics is that the production of statistics is free from political pressure. One way that this is ensured is through the role of Chief Statisticians and Heads of Profession for Statistics, who are responsible for upholding the standards of the Code within public bodies. As part of this role, they have sole authority for deciding on the content and timing of the release of regular and ad hoc official statistics.
In some instances, our casework investigations highlight the need to protect the independence and voice of statistical leaders, as demonstrated in the case study below. In this case, we intervened to reinforce the independence of Scotland’s Chief Statistician as a result of casework we carried out on the Scottish Health and Wellbeing Census. Our intention in such cases is to empower leaders in the statistical system to uphold the standards of the Code.
Case study – Scottish Health and Wellbeing Census
In 2022, we were contacted by several individuals who raised concerns regarding multiple aspects of the new Health and Wellbeing Census, which had been taking place in schools in Scotland during the 2021/22 academic year. Our initial casework investigation promoted us to undertake a more comprehensive compliance check of the survey, the results of which were shared with the Scottish Government in July 2022. We made several recommendations and requested that the Scottish Government review its approach to developing questions for the survey and publish the outcomes of the review.
On 13 February 2025, we wrote again to the Scottish Government to highlight that, 30 months later, the outcomes of the review had still not been made public. We also requested assurance on the processes and governance within the Scottish Government regarding the independence of Scotland’s Chief Statistician, in line with our expectations under the Code of Practice for Statistics.
On 28 February, the Scottish Government published its background report into the Health and Wellbeing Census. The Chief Statistician subsequently wrote to us on 3 March to reassure OSR that the importance of independent decision making around statistics is fully recognised across the Scottish Government.
Promoting intelligent transparency
Since 2022, we have promoted our concept of intelligent transparency to ensure that statistics and data serve the public good. Intelligent transparency is about proactively taking an open, clear and accessible approach to the release and use of data, statistics and wider analysis. There are three core principles supporting intelligent transparency: equality of access, enhancing understanding and analytical leadership. Intelligent transparency is at the core of many of the practices outlined in the Code of Practice for Statistics.
The issues highlighted through our casework have been key to refining our approach to intelligent transparency. Casework has also provided an important mechanism through which we can promote and illustrate this concept, showing how different areas of our regulatory activity can support and reinforce each other.
Over the 2024/25 period, we have increasingly sought to apply the principles of intelligent transparency to the cases we investigate. The case study below illustrates a public casework intervention that OSR made to protect one of the principles of intelligent transparency – enhancing understanding – to ensure that statistics are used appropriately. The case concerns the misleading use of a figure by the Department for Work and Pensions at the time of a high-profile and controversial policy announcement on the composition of Universal Credit.
Case study – Universal Credit claimant figures
Following the UK Government’s announcement of its intention to make changes to the benefits system in early 2025, we received several complaints about a press release published by the Department for Work and Pensions (DWP) on 13 March 2025. The press release included a claim that the number of people on the disability element of Universal Credit with no requirement to look for work had seen a 383% rise in less than five years.
Upon investigation, we determined that the claim presented an entirely misleading picture to the public. This was due to the claim not recognising that the majority of the increase was 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 were accounted for, we found that the actual increase in the number of people claiming disability elements of Universal Credit was 50% between February 2020 and August 2024.
After raising our concerns with statisticians in DWP, the press release was updated. However, we judged that these changes did not go far enough to meet our standards of intelligent transparency. We recognised that engagement with senior leaders was necessary to ensure that the statistics were communicated to the public appropriately and to support users in a sensitive area of public debate.
In a public letter to the Permanent Secretary of DWP, we requested that the press release be amended to remove the reference to the 383% figure, and that this figure not be used going forward. In addition, we emphasised that 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.
Following our intervention, DWP took swift action to address our concerns and remove the 383% figure. DWP’s response to us on 24 April 2025 also emphasised the department’s commitment to involve statisticians at all stages when communicating official statistics, with appropriate oversight from the Head of Profession.
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Reinforcing the quality of statistics
Our casework function enables us to make recommendations for improvement and seek positive changes from statistics producers in addition to our routine, and more intensive, programme of assessments and systemic reviews. The 2024/25 period saw multiple instances of our casework interventions resulting in the quality of statistics being improved. In many cases, this was achieved through informal engagement with the producer; these cases usually see OSR sending a private response to those who raise an issue, rather than issuing a public letter. Nonetheless, public interventions are sometimes required to achieve the necessary results and impact to benefit users and provide learning for the wider statistical system. The case study below illustrates an instance from the last year where we made a public intervention to reinforce the quality of statistics.
The quality of statistics can depend in part on the suitability of data sources and the processes which inform data collection. This example concerns the sensitive issue of collecting information on sex and gender, which has been a theme of OSR’s wider regulatory work on quality over the last year. We were able to investigate public concerns about the terminology used in an NHS staff survey through applying the guidance we developed for producers on collecting and reporting data about sex and gender identity in official statistics. As a result of our work, NHS England took steps to improve its technical guidance on this topic.
Case study – Gender identity terminology in the NHS staff survey
In December 2024, we were contacted by the staff network organisation SEEN in Health regarding the design of the NHS staff survey. The organisation raised concerns about the conflation of the terms “sex” and “gender”.
After reviewing the issue through our casework function, which included applying our own guidance to statistical producers on sex and gender identity, we determined that NHS England should look to provide clearer guidance and definitions to both survey respondents and data users in future surveys. This review will take account of our guidance, the recently updated Gender Identity Data Harmonisation Guidance produced by the Government Statistical Service, and the outcome of the Supreme Court ruling on the definition of “woman” in the Equality Act 2010, which was pending at the time of the case.
In the interim, NHS England has 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. As part of our routine regulatory work beyond casework, OSR will continue to engage with NHS England, with a view to providing support on this important and sensitive issue.
Reflecting on our remit
While our statutory remit covers official statistics, we take a broad view of what falls within our scope. For many who see the publication of numerical information, the distinction between official statistics and other data may not always be clear. In recent years, we have seen an increase in the number of cases which fall outside our formal remit. In these situations, we consider how OSR’s intervention could improve the use or interpretation of a statistic, how our intervention might be perceived and what positive impact we hope to have on the statistical system or public debate. As a result, we may consider issues that could be perceived as official statistics, whether or not they are formally classified as official statistics. When we consider cases that are outside our usual area of focus, but nevertheless relate to the presentation of quantitative information in the public domain, our focus is on how the use of these numbers complies with our principles of intelligent transparency.
This year, the issues we encountered through casework prompted us to start discussions to explore the idea of the public sphere, looking at the implications of a changing public sphere for statistics and regulators. The public sphere is an area in social life where individuals can come together to freely discuss social problems and form public opinions. This is not necessarily a physical space; rather, it is about how and where we interact and communicate. In an ideal world, the opinions that are formed through these interactions influence our elected representatives and the decisions made by government.
Although we are at an early stage in this work, it is hoped that it and our research on how official statistics shape personal decisions will improve our understanding of the statistical user landscape. By doing so, we can become more effective in communicating our remit and improve our casework service.
We also recognise that ours is just one of many voices which can positively impact the use of statistics in public life. As such, we continue to have valuable and mutually supportive relationships with organisations such as Full Fact and BBC Verify. These organisations often come across, or are requested to investigate, the same issues which are raised with OSR, although their remits are much broader and not restricted to official statistics. On occasion, this can result in us passing cases on to Full Fact or BBC Verify, particularly for cases which sit outside our formal remit. We also collaborate to address cases together when appropriate; the Full Fact Report 2025 referenced our recent support to Full Fact in working with NHS England to correct claims in an interactive report on waiting lists.
The case study below shows a significant and sensitive casework investigation which encouraged us to reflect on our remit and consider how research and data beyond official statistics impact decisions made in wider society. In this example, we were asked to consider the statistics presented in a research report on gambling harm. After our investigation, we shared our findings and recommendations on an informal, advisory basis, focusing on the importance of the clarity and transparency of this information.
Case study – Research publication on gambling harm data
In May 2024, OSR was contacted by an external organisation regarding a 2023 report on “The economic and social cost of harms associated with gambling in England” published by the Office for Health Improvement & Disparities (OHID). The 2023 report was an update to a 2021 report published by Public Health England (PHE). The complainants were concerned that there were significant methodological, factual and mathematical problems with PHE’s and OHID’s estimates of deaths by suicide associated with “problem gambling”.
While the report contained some official statistics, we recognised that the research and data it presented did not constitute official statistics and therefore fell outside OSR’s formal regulatory remit. Nonetheless, owing to the importance and sensitivity of the subject, OSR decided to undertake a casework investigation in order to provide informal advice and guidance to the crown body which had published the report. During the investigation, the OHID team engaged constructively with us and valued our insight.
We communicated our findings to OHID in a public letter from the Director General in September 2024. In this letter, OSR commended OHID for its efforts in producing the report, which offered valuable insights into the economic and social costs of gambling-related harms. We also made several advisory recommendations on the use of language and the need for additional clarity around the strength of the evidence used to estimate the costs of gambling.
OHID’s open and proactive engagement with OSR on this sensitive matter demonstrated a positive approach to enhancing public understanding around data presentation and the value of research in informing important social issues. It also reflected how OSR’s formal regulatory remit does not encapsulate the entirety of our work or ability to influence positive changes beyond the realm of official statistics.
Improving our casework service
The volume of casework that we receive continues to demonstrate the value of our casework function as one of OSR’s four main regulatory tools. We are always looking for ways to improve the casework service to ensure that we are responsive to the public’s needs, addressing issues appropriately and in a timely manner.
Since our last report, the average time it has taken for us to investigate and respond to casework queries has decreased. Our median number of days to close a case in the 2024/25 period has decreased slightly to 13 days, compared with 14 days in 2023/24 and 27 days in 2022/23. This decrease is due in part to a concerted effort across OSR to prioritise casework among our regulatory tools as the area where we can most quickly have an impact on both the statistical system and the information which is informing public discussion.
In last year’s annual casework report, we outlined how we want to further improve our casework by focusing on the perspective of the complainant. In September 2024, we launched a casework feedback survey for those who raise concerns. The survey comprises six questions and is sent to all complainants in the month after OSR completes and closes the relevant case. Through analysing and acting on the survey responses, we aim to improve the casework service, including by reflecting on the timeliness of our interventions, the transparency of our investigative process and how we communicate our regulatory judgements.
While we had intended to share the overall findings from the initial survey responses in this year’s casework report, the volume of responses has not yet been sufficient for us to draw any significant conclusions. We will continue to analyse the responses and will provide a more substantial update in a year’s time. In the meantime, we are looking to streamline how new cases are raised through our website and considering new ways to present key casework management information to improve transparency.
What’s next?
OSR is currently refreshing the Code of Practice for Statistics to ensure it continues to meet the needs of its wide and evolving audience. To complement this work, we will consider how our approach to casework can be more overtly grounded in the revised Code in the future. This will help to make the link clearer between our regulatory decisions regarding casework and the Code as the foundation document of our regulatory activity. The integration of intelligence transparency principles into the revised Code will also impact how we communicate our casework findings.
Casework will continue to be at the centre of OSR’s regulatory activity in the future and will therefore influence the development of OSR’s new 5-year strategy, which is due to be published in later in 2025.
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