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Office for Statistics Regulation written evidence to the Levelling Up, Housing and Communities Committee’s inquiry into Funding for Levelling Up

Dear Mr Betts,

I write in response to the Levelling Up, Housing and Communities Committee’s inquiry into Funding for Levelling Up.

The Office for Statistics Regulation (OSR) is the independent regulatory arm of the UK Statistics Authority and provides independent regulation of all official statistics produced in the UK. We aim to enhance public confidence in the trustworthiness, quality and value of statistics produced by government through setting, and assessing compliance with, the Code of Practice for Statistics.

Like the Committee, we strongly advocate for the transparency of data that are in the public interest and required for key decisions underpinning policy making. Our expectations are outlined in our guidance on intelligent transparency. We would like to see greater clarity and transparency around the data that are required to understand progress against the UK Government’s levelling up policy commitments. This includes both data on funding for levelling up policies and the metrics that will be used to measure the outcomes. Where there are new or existing data of sufficient quality and at the level of granularity users require, we would like to see greater transparency and accessibility of those data.

 

We are aware that the Committee wrote to Neil O’ Brien MP, then Parliamentary Under Secretary of State for Levelling Up, asking for further information around the various funding programmes for levelling up policies and his response, accompanied by a funding map dataset, was published on the Committee’s webpages. As far as we can tell, this has not been published elsewhere. We are aware that the Committee has concerns about the table that was provided, which is limited in terms of its utility, and the guidance needed for a comprehensive interpretation of the figures. There will clearly be interest from the Committee and others in updated versions of this table as the levelling up agenda progresses, and other funds are allocated.

We see that there is a case for developing a more publicly accessible version that could sit on gov.uk, rather than a future update coming out again as an annex to a committee letter. This separate publication could then include the necessary additional information required to interpret the data in a more informed manner and be developed to improve its utility for understanding the outcome of bids for different levelling up funding streams, as well as clarity on periodicity and sources of funding. This should be published in an accessible form, in line with the Code of Practice for Statistics.

We corresponded with Department for Levelling Up, Housing and Communities (DLUHC) from August 2021 to November 2021, asking for greater transparency around data on the Levelling Up Fund and the related ‘prioritisation of places model’. This led to a positive outcome and a commitment from DLUHC to the data that inform key decisions available. When the next round of levelling up funding allocations is announced we expect to see published data that is supported by a methodology and links to the source data. This should allow users to recreate the funding model for the allocation of priorities areas and enhance public confidence in the decisions that are being made.

DLUHC has set up the Office for Local Government (Oflog) which is tasked with bringing together data to understand local government performance in relation to value for money and publishing its conclusions in an annual report. This information could be used to monitor local authorities’ performance against aspects levelling up objectives based on the funding that they receive and may add to the case for developing a published levelling up funding series. We also note that the Levelling Up White Paper outlines that “devolved governments are best placed to deliver certain services like health and education” – as a result at some point there may be a need to publish transparent information on the performance of these services, in relation to the funds allocated to them.

 

We understand that the Office for National Statistics (ONS) is receiving funding from DLUHC to develop subnational data and has started publishing its subnational data explorer. The data explorer provides helpful explanations and includes a ‘data dictionary’ that accompanies the supporting dataset. We think the ONS’s approach to publishing subnational data could serve as a good example for other departments looking to publish their own data relating to levelling up policies in a transparent and accessible way.

Please let me know if you have any questions or if I can support the Committee further in its inquiry.

Yours sincerely,

Ed Humpherson 

Director General for Regulation

Office for Statistics Regulation written evidence to the DCMS Sub-committee on Online Harms and Disinformation inquiry on misinformation and trusted voices

Dear Mr Knight, 

I write in response to the inquiry Misinformation and trusted voices, as conducted by the DCMS Sub-committee on Online Harms and Disinformation.  

Which organisations are the most trusted sources of information in the UK?  

The Office for Statistics Regulation is the independent regulatory arm of the UK Statistics Authority and provides independent regulation of all official statistics produced in the UK. It aims to enhance public confidence in the trustworthiness, quality and value of statistics produced by government through setting, and assessing compliance with, the Code of Practice for Statistics1. In addition, one of our key roles is to use our voice to stand up for statistics and to represent the public, monitoring and reporting publicly where we have concerns about the dissemination and use of statistics and highlighting good practice. 

The Code of Practice for Statistics has three pillars: Trustworthiness, Quality and Value. The three pillars work together to provide the conditions to support public confidence in statistics, which relates directly to the question the Committee is asking. In particular, we distinguish trust – a belief on the part of individuals – from trustworthiness – a property of organisations. Trustworthiness is about providing evidence that the systems, processes and governance surrounding statistics are effective. However, we never consider trustworthiness in isolation. We consider all three pillars to determine whether statistics are fully compliant with the Code of Practice and can be designated as National Statistics. This designation demonstrates to users that they can have confidence in the relevant official statistics. 

One source that can give some insight into levels of trust in official statistics is the 2021 study of public confidence in official statistics. It found that, amongst people who responded, there was high confidence in the statistical system. While respondents did not necessarily know about the Authority or the OSR, there was strong support for our role, with 96% of respondents agreeing there should be an independent body to speak out against the misuse of statistics and 94% agreeing that such a body should ensure that statistics are produced free from political interference. Regarding the Office for National Statistics (ONS), the largest producer of official statistics in the UK, 87% of respondents reported that they trusted ONS statistics. The public value of statistics has also been shown through 92% of respondents who had used COVID-19 data reporting them being useful. Although this is only one source, and we are careful not to place too much weight on a single survey result, we do consider that this provides some reassurance around public confidence in official statistics. 

In addition to official statistics producers, there is a wider ecosystem of statistics and data. Many of these other sources of statistics and data inform policy and public debate and it is important that they are used for the public good. We encourage producers outside of the official statistics producer community to apply the Code of Practice for Statistics on a voluntary basis. Our annual award for Statistical Excellence in Trustworthiness, Quality and Value recognises those who voluntarily apply the core pillars of the Code of Practice for Statistics. 

Is the provision of authoritative information responsive enough to meet the challenge of misinformation that is spread on social media? 

Our view is that the best way to combat misinformation is to ensure that information that is trustworthy, high quality and high value is made available to the public. In this way, the good information can drive out the bad. 

However, we recognise that it is hard to live up to this ideal. The experience of the pandemic is instructive. As we noted in our recent State of the Statistical System report, there are a variety of organisations and individuals commenting on the use of statistics by government. The COVID-19 pandemic in particular was associated with an increase in the role of citizens as ‘armchair epidemiologists’. We wrote a blog4 highlighting how open data enabled great work to be done to communicate data on COVID-19 publicly from outside the official statistics system, including on social media. This demonstrated the changing statistical landscape of increased commentary around official statistics at its best. 

Since the pandemic there has continued to be an increased interest in and scrutiny of statistics. This is a positive for the statistics system but also brings risk. Much discussion of statistics takes place on social media with increased risks around misuse, misinterpretation and ‘echo chambers’. Official statistics producers need to be aware of these changes in the use of statistics. 

Areas that we highlight in our report that can help official statistics producers meet the challenge of misinformation that is spread on social media include: 

  • improving how uncertainty in statistics is communicated to bring effective insight; 
  • an increase in government statisticians challenging the inappropriate use of statistics and engaging directly with users to support understanding of statistics; and  
  • intelligent transparency around statistics, data and wider analysis. 

 

Intelligent transparency means proactively taking an open, clear and accessible approach to the release and use of data, statistics and wider analysis. As set out in our regulatory guidance on transparency, intelligent transparency is informed by three core principles: equality of access, enhancing understanding and analytical leadership. It is about more than just getting the data out there. Intelligent transparency is about thinking about transparency from the outset of policy development, getting data and statistics out at the right time to support thinking and decisions on an issue, supporting the wider public need for information and presenting the data and statistics in a way that aids understanding and prevents misinterpretation. 

In conclusion, a constant refrain of the OSR is that it is important to ensure that the bad data does not drive out the good. However, as long as producers have the right approach, based on trustworthiness, quality and value, good statistics can thrive. 

Please let me know if any questions or if I can support the Committee further in its inquiry. 

Yours sincerely  

Ed Humpherson  

Director General for Regulation 

Office for Statistics Regulation written evidence to the Scottish Parliament’s Covid-19 Recovery Committee’s inquiry on pre-budget scrutiny

Dear Ms Brown, 

I am writing to make you and the Committee aware that on 30 August 2022 the Office for Statistics Regulation (OSR) has published an update to our March 2021 review of the COVID-19 Infection Survey (CIS). The CIS measures how many people living in Scotland, Wales, Northern Ireland, and England test positive for a COVID-19 infection at a given point in time, regardless of whether they experience symptoms. In Scotland, the statistics contribute to ongoing surveillance of the coronavirus pandemic, along with other sources such as genomic sequencing to identify new variants, testing in health and social care settings, and wastewater surveillance.  

The CIS is therefore a key component of public health surveillance in Scotland. In line with its importance, we have maintained a close regulatory focus on how the survey is conducted and on how the results are calculated and presented. The background to our latest review is that in June 2022, the Office for National Statistics (ONS) announced changes to the survey, introducing a digital questionnaire and sending swab and blood sample kits by post. These changes reflected plans to maintain a scaled back version of the CIS set out by the UK Government in its Living with COVID-19 plan.  

In light of the ONS’s changes, we agreed with the ONS that we would undertake a further review of the statistics against the Code of Practice for Statistics. This update looks at whether, and to what extent, the statistics from this survey continue to serve the public good.  

Our review highlights the ongoing value of the CIS. Given the cessation of the REACT study and changes in testing regimes by governments across the UK, these statistics are now the most up-to-date, reliable source on COVID-19 infections. They contribute to scientific advice provided to governments, including the Scottish Government, informing decisions on the ongoing management of the pandemic. In Scotland, the statistics are reported on weekly by Public Health Scotland in its COVID-19 statistical report. Public Health Scotland states that the statistics are the “current best understanding of community population prevalence”. The statistics from the CIS contribute to the estimate of the reproduction (R) number for Scotland, also published in Public Health Scotland’s report. This provides an assessment of whether the pandemic is shrinking or growing. And there is a high level of public interest in the survey – people really value the statistics and many use them to make day-to-day decisions, including potentially serious decisions for those vulnerable to COVID-19.   

Our review makes several recommendations to the ONS regarding ongoing improvements to the statistics: 

  • The ONS should ensure that devolved administrations have appropriate input at the programme level. The ONS has built good working-level relationships with the devolved administrations, including statisticians in the Scottish Government. However, we consider that devolved administrations would benefit from increased engagement at a senior level, for example to ensure that they can input to decisions relating to changes to the survey.  
  • The ONS should continue to inform users about the impacts of the change in mode to digital data collection on the statistics. We found that for the statistics to remain as valuable as possible, it is important for many users, particularly those in the devolved administrations, that granular breakdowns are still available following changes to the survey mode. We are encouraged to see ONS’s plans to understand and publish information about the change in mode. This includes information on any impact on the response rates and sample, and therefore the representativeness of the survey. The ONS recently published their initial findings on the effects of the change of mode which offers a first insight into many of these aspects. 
  • The ONS should ensure it keeps users informed about development plans, even if these plans are tentative and subject to change. While we appreciate that the ONS is working in a fast-moving environment and that decisions about the survey may sit with other partners, we consider that it could have done more to keep users informed in a clear and timely way about planned or potential changes to the survey. It will be particularly important for the ONS to keep users informed about the future of the survey as the financial year ends.
  • The ONS should also consider how the CIS can be adapted to play a role in understanding public health in future. The coronavirus pandemic reinforced the need for statistics to inform society about public health. In our review of lessons learned for health and social care statistics during the pandemic we highlighted the need for statistics producers across the UK to continue to develop outputs which go beyond operational data in order to support a better understanding of public health.  

I know the Committee is currently holding evidence sessions for their pre-Budget scrutiny on the COVID-19 strategic framework and are looking specifically at surveillance measures. I hope this letter will help inform the Committee’s work on the subject. 

Please do let me know if you have any questions.  

Yours sincerely  

Ed Humpherson
Director General for Regulation 

Office for Statistics Regulation written evidence to the Procedure Committee’s inquiry on correcting the record

Dear Ms Bradley,

I write in response to the Committee’s call for evidence for its inquiry Correcting the record.

The UK Statistics Authority and the Office for Statistics Regulation (OSR), as its regulatory arm, have a responsibility to ensure that official statistics meet the public good. We provide independent regulation of all official statistics produced in the UK, and aim to enhance public confidence in the trustworthiness, quality and value of statistics produced by government. We do this by setting the standards official statistics must meet in the Code of Practice for Statistics. We ensure that producers of official statistics uphold these standards by conducting assessments against the Code. Those which meet the standards are given National Statistics status, indicating that they meet the highest standards of trustworthiness, quality and value.

We also report publicly on systemwide issues and on the way that statistics are being used, celebrating when the standards are upheld and challenging publicly when they are not, intervening when statistics are either misused publicly, or quoted without sources being made clear. Our interventions policy explains how we make these judgements in a considered and proportionate way.

Key to our interventions is the ask that people practise intelligent transparency. Transparency and clarity support public confidence and trust in statistics and the organisations that produce them and minimises the risk of misinterpretation of statistics and data. Transparency allows individuals to reach informed decisions, answer important questions and provide a mechanism for holding governments to account. Statistics and data also underpin successful implementation of government policies, and individuals’ views on the effectiveness of policy decisions.

Intelligent transparency is informed by three principles:

  • Equality of access: Data quoted publicly, for example in parliament or the media, should be made available to all in a transparent way. This includes providing sources and appropriate explanation of context, including strengths and limitations.
  • Understanding: Analytical professions need to work together to provide data which enhances understanding of societal and economic matters, including the impacts of policy. Governments should consider data needs when developing policy and be transparent in sharing analytical and research plans and outputs with the public.
  • Leadership: Organisations need strong analytical leadership, within and beyond analytical professions. Decisions about the publication of statistics and data, such as content and timing, should be independent of political and policy processes. These decisions should be made by analytical leaders, who should also be given freedom to collaborate across organisational boundaries to support statistics that serve the public good. Their expertise and decision-making authority should be endorsed by Permanent Secretaries.

As tools for understanding public policy, statistics and data rightly belong at the heart of Parliamentary debate. They can be a powerful support to an argument. In the pressured environment of an oral debate, it is only natural that some of these references to statistics, though made in good faith, will be misremembered, unclear, or misattributed. In these circumstances, it is always welcome when MPs make the effort to furnish the record with clarifications or additional information about their sources. This not only ensures that the House is fully informed, but also meaningfully improves the quality of media reporting and subsequent public debate.

At other times an MP may quote statistics correctly but confuse data from a private source with that already in the public domain. In particular, Ministers (who under the Ministerial Code are required to be mindful of the Code of Practice for Statistics) have access to a wide range of published and unpublished information from their departments and should take care to rely on the former when making their statements. However, as set out in our guidance for the transparent release and use of statistics and data, when unpublished information is used unexpectedly, statistical officials in Government departments can play their role in setting the record straight by publishing the information as soon as possible in an accessible form, ideally on the same day. This can be done via an ad-hoc release, which need not be long, or technical. For example, the Department for Work and Pensions has a page dedicated to ad hoc statistical analyses.

Our aim, one that we would hope the Committee agrees with, would be to see intelligent transparency being the default for all statistics and data, including those used by Ministers and parliamentarians.

Please let me know if you have any questions.

Yours sincerely

Ed Humpherson
Director General for Regulation

Office for Statistics Regulation correspondence with the Levelling Up, Housing and Communities Committee on transparency of data related to the Levelling Up Fund

Dear Mr Betts,

Accessibility of Levelling Up policy funding stream data

I write regarding your recent letter to Neil O’Brien MP, Parliamentary Under Secretary of State for Levelling Up, the Union and Constitution, at the Department for Levelling Up, Housing and Communities (DLUHC), requesting access to data on the various Levelling Up policy funding streams.

At the Office for Statistics Regulation (OSR), we share your support for the transparency of data that is in the public interest and required for key decisions underpinning policy making.

You may be aware that we corresponded with DLUHC from August 2021 to November 2021, asking for greater transparency around data on the Levelling Up Fund and the related ‘prioritisation of places model’.

OSR expects such data to be made publicly available, as outlined in our guidance on intelligent transparency. This guidance has been endorsed by the Civil Service Chief Operating Officer, Alex Chisholm.

Please let me know if there is anything you would like from us in support of your request, or if you would like a meeting to discuss further.

Yours sincerely

Ed Humpherson

Office for Statistics Regulation follow-up written evidence to the Science and Technology Committee’s inquiry on UK science, research and technology capability and influence in global disease outbreaks

Dear Mr Clark,

On 2 March 2022, I gave oral evidence to the Science and Technology Committee. In my evidence in response to a question about the approach to measuring excess deaths I referred to the Office for National Statistics (ONS) approach, stating that: “For the five-year rolling average excess deaths, ONS has decided for 2022 to drop 2020 from the five-year calculation… It is 2016, 2017, 2018, 2019 and 21, and it has dropped 2020 because 2020 had such an unusual peak of deaths.”

I wanted to clarify that there are a number of ways to measure excess deaths, that is, the difference between the expected number of deaths and the actual number of deaths in a given period of time. The ONS headline approach, shown in the weekly deaths publication is as I described above and has been agreed across the devolved administrations. ONS publications also refer to excess deaths based on the five-year average from 2015 to 2019. ONS has published a blog explaining more about its choice of five-year average.

As the ONS blog notes, more complex methods can also be used to calculate expected deaths. The Office for Health Improvement and Disparities (OHID) uses a more sophisticated modelling approach, taking into consideration the ageing population, differing mortality trends in subgroups of the population and variation in registrations around bank holidays. OHID developed a different method to that of ONS because it needed more accurate data for operational decision making during the pandemic. OHID continues to use the years prior to the pandemic (2015-2019) as the five-year baseline for its measure of excess deaths.

I would be happy to discuss this further if you would find it helpful.

Yours sincerely,
Ed Humpherson

Director General for Regulation

 

Office for Statistics Regulation oral evidence to the Science and Technology Committee’s inquiry on UK science, research and technology capability and influence in global disease outbreaks

On Wednesday 2 March 2022 Ed Humpherson, Head of Regulation at the Office for Statistics Regulation, gave oral evidence to the Science and Technology Committee’s inquiry on UK science, research and technology capability and influence in global disease outbreaks; specifically on statistics and modelling.

A transcript of which has been published on the UK Parliament website.

Office for Statistics Regulation written evidence to the Public Administration and Constitutional Affairs Committee’s inquiry on Coronavirus Act 2020: two years on

Dear Mr Wragg,

I write in response to the Committee’s call for evidence for the inquiry ‘Coronavirus Act
2020: two years on’; specifically, the transparency surrounding the use of data in decision making relating to the renewal of the Coronavirus Act 2020.

During the pandemic, the response of statistics producers to publish close to real-time data
was remarkable – for example, daily updates on COVID-19 cases and deaths. Producers
demonstrated the ability to consider user needs when balancing timeliness against quality
and strong analytical collaboration resulted in valuable, high-quality statistics.

As noted in our written evidence to your inquiry on data transparency and accountability:
COVID-19, throughout the pandemic the Office for Statistics Regulation (OSR) has called
for greater transparency of data related to COVID-19. In May 2020 we set out our
expectations on the use of management information by government and other official
bodies, and followed up in November 2020 and July 2021.

As you know, unfortunately we had to intervene on multiple occasions regarding instances
of data being quoted publicly that were not in the public domain, which had been used to
inform decision-making. These ranged from data quoted during press briefings, testing data, and data to inform quarantine policy around red-list countries. These were key decisions and announcements made with evidence that the public, media, and Parliament should have been able to scrutinise immediately.

However, two years on, we can see that progress has been made to support the quick
publication of new statistics and data which inform decision-making. It is encouraging that,
when we have raised concerns with producers recently, often during challenging
circumstances such as the emergence of new variants, these have been resolved more
quickly. We discussed the overall improvements in our October 2021 report: ‘improving
health and social care statistics: lessons learned’ where we noted how essential
transparency is for building public trust in statistics and retaining public confidence in
government decisions.

Transparency has been a big theme of our work. In October 2021 we published a blog
setting out our own priorities: build our evidence base of good examples of transparency,
continue to intervene when necessary, and work with external organisation and
governments to make the case for transparency. We are grateful for the Committee’s
support on these issues, and we will continue to keep you updated on this work.

I hope this is a useful summary for the Committee, and please do let me know if I can be of
further assistance.

Yours sincerely
Ed Humpherson
Director General for Regulation

Office for Statistics Regulation oral evidence to the Scottish Parliament’s Health, Social Care and Sport Committee’s inquiry on Data and Digital Services in Health and Social Care

On Tuesday 23 November 2021 Ed Humpherson, Head of Regulation at the Office for Statistics Regulation, gave oral evidence to the Scottish Parliament’s Health, Social Care and Sport Committee for their inquiry on Data and Digital Services in Health and Social Care.

A transcript of which has been published on the Scottish Parliament’s Website.