Conclusion

We trust that our comments will be of assistance in consideration of the proposals generally. We consider any future arrangements should seek to enhance inclusion and equality in the UK’s framework of official statistics and, evaluating the proposals in light of their implications for inclusivity, we are not assured that the proposals achieve this. In summary, the Advisory Committee is concerned that:

• in the proposed admin-based statistical framework there are likely to be 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 (such as distrust in government) could well be greater in the proposed new framework than they are in the case of the regular census;
• there will be additional challenges to conducting analysis relevant to inclusion and equality because of a range of technical issues such as differing data standards and a range of practical issues such as sample sizes (where sample surveys have to be used to fill gaps in the admin-based data), as set out in the Inclusive Data recommendations report.

We recognise that ONS has proposed various programmes of work to mitigate some of these issues and that a great deal hinges on the success of these plans for mitigating the current acknowledged weaknesses with respect to inclusivity of the existing linked administrative datasets. However, the very early stage of the development of these plans, and the technical challenges involved, mean that it may be much more realistic to retain the 2031 Census while simultaneously developing and evaluating these plans. Experience suggests that there is a serious risk of reputational damage to ONS if the proposals are implemented before the mitigations have been fully developed and shown to be effective.

We consider further consideration should be given to the range of factors we have highlighted, as well as the responses to the Consultation Document and the Equality Impact Assessment to ensure equality matters are fully taken into account, before making any irrevocable decisions regarding the future of population and migration statistics.