Recommendations and responses
Recommendation 1
Ensure that the recommendations in its reviews and assessments provide more explicit guidance on the actions that need to be taken by the producer and with a clearly specified time frame for completion for each recommendation.
OSR’s original response:
We agree and will implement this as stated.
We will continue to develop our recommendations to make them clearer. A key way that we aim to do this is to be explicit on the desired beneficial outcome from making the change, or the risk that the change is expected to manage. We will also aim wherever possible to provide guidance on the “how”, and in doing so we will recognise that as the producer body looks into taking action, or because circumstances change, there may be alternative ways of delivering the desired outcomes and impact. We will also ensure that we are clear whether our suggested actions are required, recommended or suggested.
Our assessment reports currently include a timescale for reporting back to OSR; we will ensure that we are clear on required timescales for action to be taken resulting from other projects, including being clear in those cases where there may be no specific timescale, or the timescale is flexible.
Updated response
We have now fully implemented this. We have produced guidance for our regulators to help with drafting recommendations and requirements, which covers the points made in our initial reply. We will reinforce these points through new desk guidance being prepared for the regulatory team, and as part of induction and regular feedback to staff.
We intend to update our published guidance on our regulatory work, and will add to that that we would aim to ensure that our requirements and recommendations are clear on the benefit to be achieved, how those benefits may be achieved and to what timescale.
Recommendation 2
Require that producers publish a response to a review within six weeks of the review’s publication, setting out how it intends to act on all recommendations in that review.
OSR’s original response:
We cannot strictly require producers to publish a response but agree that we should ask producers to publish a response and will work through the practicalities of extending this to our non-assessment work.
It is already widespread practice within our assessments for producer bodies to respond to the assessment describing their intended actions – either through a high-level letter, a formal action plan, or both. We also request or are offered such responses in a small proportion of our shorter reviews. We will consider how to apply this principle proportionately across our different regulatory projects, recognising that some of our reviews are short and the findings may not lead to the need for a formal action plan. We recognise that publishing a response within six weeks may be a suitable default and will seek to agree with producer teams the appropriate timescale for a response in each project. We will pay particular regard to resourcing pressures within producer teams especially during busy times of the statistical production process.
Updated response
Our outputs are now clear about what form of response should be published and when. We will continue to use six weeks as a default, recognising that we will decide on a case-by-case basis, and that in some cases a formal published action plan would not be required. We will incorporate this approach into our revised compliance review guidance.
Recommendation 3
Monitor and report on progress against the recommendations in its reviews by regularly updating the review Annex, in which the findings and recommendations are enumerated against the pillars of the Code [of Practice for Statistics]. Review reports should be considered ‘live’ documents, with progress against recommendations updated when milestones and deadlines become due.
OSR’s original response:
We agree in principle and will work through the practicalities of extending this to our non-assessment work.
For each of our assessments we publish details of actions taken by the producer body, and OSR’s response, alongside the confirmation or awarding of National Statistics designation. We will consider how to develop this practice in the following ways:
- Weighing the potential benefits of publishing progress updates to the table more frequently against the administrative burden of so doing.
- Applying proportionately to our other projects, taking specific care to avoid being burdensome for either OSR or producer bodies especially in the smallest reviews.
Updated response
We have considered how best to achieve regular public reporting of the follow up to our reviews, balancing the need for transparency and accountability, whilst avoiding unhelpful burden on statistical producers and the regulatory team. For those projects that are important and high profile enough to require a report back, we will achieve this through asking Chief Statisticians, Heads of Profession for Statistics or other relevant senior statisticians to publish regular updates on progress. We will specify the frequency and form in our reports alongside the ask relating to the publication of an action plan (recommendation 2).
Recommendation 4
Implement a penalty for failure to comply with review recommendations within the specified timeline. This might be a requirement by the head of the unit being reviewed to write a letter to the National Statistician explaining why the recommendation has not been actioned.
OSR’s orginal response:
We agree that we should consider how to respond to failure to comply with our recommendations and will work through the practicalities of extending this to our non-assessment work.
We consider that as a minimum it would be appropriate for producer teams to write to the Director General for Regulation (as head of OSR) rather than the National Statistician to describe why recommendations haven’t been actioned, although recognise that we have no formal powers to require this. Writing to the Director General for Regulation reflects our current practice for other correspondence about failure to comply with the Code of Practice for Statistics. We will consider what further interventions may be appropriate, recognising that we have few formal powers or sanctions that we can apply beyond the removal of National Statistics for statistics that are designated as such.
Updated response
We consider that the improvements made as a result of recommendations 2 and 3 will significantly reduce the number of times we need to require a report back on failure to address our requirements and recommendations.
We will use our ongoing engagement with statistical teams to ensure compliance. In cases where action falls short of our expectations, we may intervene privately or publicly with the aim of ensuring accountability. We will add to our public-facing documentation that we will in some cases write publicly if we feel that progress against our requirements has been too slow to be clear that this route of accountability is open.