ONS’ Equality Impact Assessment of the FPMS proposals

The Future of Population and Migration Statistics (FPMS) proposals by ONS were accompanied by an Equality Impact Assessment which reviews the statistics that are currently offered under the existing statistical system against what is expected to be available under the proposed new system, and plans for further development. It shows that it is likely that there will be some major gaps in the availability of administrative data on some protected characteristics and that therefore supplementary material, probably from sample surveys, will be needed to plug these gaps. How this will be done, however, and how reliable the estimates will be, is not yet clear. These plans are at an early stage or likely to be subject to availability of funding, so it is difficult to be precise about the equality implications of the proposals. However, our assessment (following detailed our questioning of the ONS) is that they are very unlikely to be as reliable as those from the census or to be available at as detailed a geographical level and this reinforces our concerns, set out above, about critical data gaps.

ONS indicates that the published Equality Impact Assessment is an interim document, which will be updated following consideration of the responses to the consultation. It will be important to ensure that full account is taken of equality considerations in any decision-making regarding the proposed changes, in line with ONS obligations under the Public Sector Equality Duty.

Opportunities for improved inclusivity in the FPMS proposals

While setting out our concerns above, we also recognise that there are potential areas where use of administrative and survey data may have potential to increase representation and inclusion. As the Consultation Document rightly points out, administrative data will enable one to include some measures such as income that are not available in the census. Census data have also been criticised for under-representation of multilingual speakers of minoritized languages because it does not recognise balanced bilingualism/multilingualism (Sebba and Ayres-Bennet, 2021, Sebba, 2019, PDF, 250KB Sebba, 2017). It is important to recognise multilingualism for social inclusion and wellbeing (Müller, L.-M., Howard, K., Wilson, E., Gibson, J., & Katsos, N., 2020)., and as an important cultural resource (Census Bill, National Records of Scotland, PDF 124KB). Given the nuance and complexity of multilingual communication in everyday life, alternative data sources such as appropriately-designed surveys, may be needed (PDF, 2.9MB).

However, one could take advantage of these opportunities without discontinuing the census. Annex II provides detail on Canada’s whole-of-government approach, led by Statistics Canada, to address equity, diversity and inclusion, which includes the use of Census of Population every five years. As in Canada, one could link administrative data on income with the census, thus enhancing the value of the census and its potential for analysis of diversity and equality. And as with the ONS proposals for using survey data to supplement administrative data, perhaps through statistical modelling, the same methods could be explored for their potential to supplement census data.