Introduction

The National Statistician’s Inclusive Data Advisory Committee was established in October 2022 by the National Statistician to provide independent advice on the ongoing implementation of the Inclusive Data Taskforce’s recommendations for improving the inclusivity of data across the UK statistical system. Like the IDTF, the Committee members are a diverse group of senior academics and civil society leaders who collectively have wide ranging equalities expertise. The Advisory Committee welcomes the opportunity to comment on the consultation on proposals for the Future of Population and Migration Statistics in England and Wales (FPMS). Our aim is to review the FPMS proposals in light of their implications for inclusivity of the data, including how they might address the findings of the Task Force.

This response sets out the Task Force findings in summary, the importance of equality considerations, our understanding of the FPMS proposals from an inclusive data perspective and details four main concerns we have identified with the proposals. It also makes some suggestions on opportunities for improved inclusivity with the proposals and provides an example of how Canada is approaching these issues which we trust will be of value to the National Statistician’s considerations.

The Inclusive Data Taskforce findings

In September 2021 the Taskforce published its report Leaving no-one behind: How can we be more inclusive in our data. Its work was guided by the fundamental principle of inclusive data, that ‘everyone in society counts and is counted and no-one is left behind’. It focused on a wide range of populations and groups that may be at greater risk of disadvantage, discrimination, or marginalisation, both generally and in our statistical picture of the UK. The Taskforce findings detailed in its report were:

• There are critical data gaps, particularly around some of the most vulnerable and disadvantaged communities in the UK.
• For some under-represented communities, barriers to participation in data collection include lack of accessibility and distrust in government.
• There are challenges to conducting analysis relevant to inclusion and equality because of a range of technical issues such as data standards, and a range of practical issues such as sample sizes and timeliness of data collection.

While considerable progress is being made, there remains work to be done to improve inclusivity of data and to ensure that the voices and experiences of at-risk populations are heard so that problems of social exclusion can be addressed.

Equality considerations and Public Sector Equality Duty (PSED)

It remains critically important to work towards inclusive data for the 21st century to ensure that information is fit for purpose in designing and delivering public services and to enhance our understanding of the needs of diverse groups in our population.

This will also help public authorities meet the requirements of the Public Sector Equality Duty to have due regard to the need to achieve the objectives of the Equality Act 2010. The objectives of the PSED are to:

1. eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Equality Act 2010
2. advance equality of opportunity between persons who share a protected characteristic and those who do not share it
3. foster good relations between persons who share a relevant protected characteristic and persons who do not share it

The Equality Act 2010 protections people from discrimination, harassment and victimisation in employment and as users of public and private services. It specifies nine protected characteristics – age, disability, gender reassignment, marriage and civil partnerships, pregnancy and maternity, race, religion or belief, sex and sexual orientation.

Ensuring the availability of inclusive data will help understanding of the situation and needs of those with protected characteristics and enable equality considerations to be taken into account in decision making.

Inclusivity and the Future of Population and Migration Statistics (FPMS)

As indicated above, our aim is to review the FPMS proposals in the light of their implications for inclusivity of the data. In summary, following the UK Government’s ambition, as set out in 2014, that “censuses after 2021 will be conducted using other sources of data and providing more timely statistical information”, ONS has now proposed a system primarily using administrative data such as tax, benefit and border data, complemented by survey data and a wider range of data sources.  It is suggested that this could produce more timely data both at a national and local authority level and would replace the current reliance on and need for a census every ten years.

The ONS recognises that there are several risks with these proposals (see Section 7 of the consultation document), notably:

• interruptions to supply of data from other organizations,
• changes to collection of data upon which ONS statistics rely,
• inability to meet needs of users through existing sources,
• drift over time in admin-based estimates, and
• effects on data standards in the public sector.

To address these risks, ONS plans to undertake various programmes of work over the next decade.

We recognise the excellent work that the ONS is doing to improve the quality and timeliness of population estimates by drawing on administrative data and support the ambition for more timely data, providing that it is accurate with respect to measurement of at-risk groups. We also recognise that many elements of the proposals are unproblematic and we welcome the inclusion of measures such as income which are not available in the census.

We also strongly support ONS’s programme of work to improve the quality and coverage of administrative data and to create linked datasets such as the Statistical Population Dataset (SPD) and the Admin-Based Ethnicity Statistics (ABES), to improve inclusiveness in areas which are not currently counted or fully considered, such as looked-after children and veterans. Indeed, we are in favour of changes which advance inclusive data generally. But we are concerned that, if an administrative-based Census were to be conducted over the coming years, supplemented by large-scale survey research to fill gaps, without reference back to a traditional Census, we would lose a crucial link in ensuring the inclusivity of official statistics and that there might be deterioration, rather than improvement, with respect to critical data gaps, barriers to participation, and challenges to analysis.

Specifically, we are concerned about four main issues:

1. Critical data gaps – Under-counting of at-risk populations
2. Critical data gaps – Lack of validation sources
3. Challenges to inclusive analysis – Lack of harmonised standards
4. Barriers to participation – Public trust

Detail on these concerns is set out below.