Memorandum submitted by the Royal Statistical
Society
INTRODUCTION
1. This note summarises the Society's current
views about the consultation paper issued by HM Treasury on Independence
for Statistics. However, the Society is in the process of consulting
all Fellows about the consultation paper and will finalise its
position by 14 June.
2. The Royal Statistical Society has long
called for legislation in statistics and has provided evidence
on this subject in the past. Shortly before the announcement last
year that the Government planned to introduce legislation, the
Society published an updated "Vision for National Statistics"
(attached) which emphasised the need for a rigorous legal framework.
3. Whilst there is much in the Government
document that we welcome, we believe it falls well short of what
is required if we are to create an independent statistical service
and restore trust in UK statistics.
EXECUTIVE SUMMARY
4. The Government consultation essentially
focuses on ONS and brings in the wider statistical system almost
incidentally. It is important that this is rectified for two reasons.
First, many of the most sensitive statistics are produced outside
ONS and second, coherent statistics on many features of society
require coordination across a range of departments. Additionally
the consultation paper gives scant mention of users of statistics
but it is essential that the statistical system takes account
of their needs.
5. We believe that the key issue is to create
an environment in which Official Statisticians, in ONS and elsewhere,
can produce statistics for public dissemination to the highest
standards that will be seen as trustworthy.
6. Our views on the points raised in the
terms of reference for your inquiry are:
— We support the proposal to make ONS
a non-Ministerial department, but more attention needs to be given
to the funding arrangements.
— We support the idea of establishing
a Statistics Board but it must be non-executive. The executive
function of the National Statistician for delivery of ONS statistics
and coordination of statistics across the system needs to be clearly
set out in the legislation.
— A statutory code of practice designed
to restore trust is needed. In addition release arrangements need
to be reformed, confidentiality assured and access to administrative
data granted for statistical purposes to improve quality and integrity.
— The Statistics Commission can be
wound up, but only if the Statistics Board is non-executive.
— National Statistics should include
all statistics produced by Government that are released for public
consumption.
— Legislation is no panacea for improving
trust. The behaviours of people inside and outside the system
will be just as important. Improvements to release arrangements
for statistics would be a powerful signal of intent.
— The professional line of accountability
for GSS Heads of Profession needs to be strengthened. In respect
of devolved administrations there is an urgent need for engagement
on statistical reform.
— Essential features of good practice
of other countries are: the critical role of the National Statistician
for the National Statistical Office and for statistical coordination,
and statutory access by the National Statistical Office to administrative
records for statistical purposes.
GENERAL COMMENTS
7. First: the Government consultation essentially
focuses on ONS and brings in the wider statistical system almost
incidentally. This is a serious misconception since many of the
most sensitive statistics are produced in policy departments or
their agencies (eg Health, Crime, Immigration, Education). Indeed
many of the factors that undermine public confidence in Official
Statistics originate in statistics produced by policy departments.
It is essential that legislative reform addresses the wider statistical
system. The National Statistician must have effective leverage
over the statistical activity in policy departments that leads
to statistics released for public consumption.
8. Second: the preceding point does not
only require that each statistical production unit operates effectively
within its own department and in response to its narrowly defined
user requirements. Coherent statistics on many features of society
require a co-ordinated activity from a range of departments. This
is obviously true in the case of UK statistics which must often
span ONS, some policy departments and the devolved administrations.
It is equally true of local statistics focussed on social exclusion,
for example, that must draw on administrative and statistical
systems spanning population, labour market, income and wealth,
education and health etc. A strong coordination of the statistical
production processes is essential together with strong influence
on priorities that span departments.
9. Third: it is useful to reflect on what
the proposed legislation is intended to achieve: put simply who
or what is being protected from what? Principled Ministers from
both administrations are on the record as stating that the statistical
framework should protect official statisticians from "people
like me" (loosely interpreted as Ministers, Special Advisors
and policy officials acting, as they see it, in support of Ministers).
A reading of the Government's proposals might lead one to the
view that the main priority was to protect the public from Official
Statisticians. This is false: certainly Official Statisticians
need to be accountable, but the key issue is to create an environment
in which Official Statisticians, in ONS and elsewhere, understand
their primary responsibility and can produce statistics for public
dissemination to the highest scientific and professional standards
that are seen to be trustworthy.
10. Fourth: Official Statistics are a public
good, supporting the needs of a wide variety of users at different
levels of government, as well as in industry and commerce, local
authorities, education and public services as well as in the European
Union and international bodies. It is vital that the statistical
system recognises this and identifies and takes into account all
users' needs in preparing production and development plans.
11. The remainder of this evidence draws
attention to our views specifically addressing in turn the terms
of reference for your Inquiry.
THE OFFICE
FOR NATIONAL
STATISTICS
12. We support the proposal to make ONS
a non-Ministerial Department within the civil service. However
we are concerned that the budget setting mechanism for ONS should
be quite independent of the annual spending review and be for
a longer time horizon. The budget must include current funding
needs together with an allowance for infrastructure renewal costs
as well as any additional recurrent costs associated with the
creation of the proposed Board and its functions. The budget should
be arrived at through a joint HMT/Parliament proposal. The Treasury
proposal to separate the Census budget from this arrangement is
unacceptable. The ongoing Census research and development costs
should be built into the ONS core budget. The abnormal and very
large Census costs associated with the Census operation itself
should be separately identified but this budget needs to be determined
well before the normal annual spending review that covers Census
day if cost-effective planning and operations are to be developed.
Hence this budget should be determined within the longer term
horizon of the ONS core budget rather than the annual spending
review.
AN INDEPENDENT
GOVERNING BOARD
13. We support the idea of establishing
a Statistics Board to advise the public, Parliament and Government
on the statistics that are needed and what needs to happen to
make sure we get them. The Board should be impartial and authoritative
and report to Parliament. However, the Government proposals need
significant modification.
14. We believe that there should be a clear
separation between operational delivery of National Statistics
(the responsibility of the National Statistician) and the oversight
role of the Board.
15. The National Statistician should have
executive responsibility for ONS and a function to coordinate
the statistical system as a whole. To be effective this coordination
function should include the following system wide responsibilities:
— Ultimate authority over the statistical
methods used.
— Ultimate authority over the timing
and content of statistical releases.
— Authority to initiate quality reviews
and to publish these.
— Professional leadership to those
producing National Statistics.
— Agreeing appointments to the highest
two levels of staff involved with producing National Statistics
outside of ONS.
— Maintaining the statutory Code of
Practice for National Statistics.
— Acting as the public spokesperson.
— Representing the UK in EU and international
meetings.
— Organising effective user consultation
mechanisms and taking account of users' needs in submitting to
the Board high level plans for statistical production together
with major priorities for significant statistical development.
In fulfilling this function a transparent financial budget of
the expenditure on statistical work throughout the system should
be presented.
16. The Board should be non-executive in
terms of the production of statistics and should ensure that the
statistical system serves the wider public interest. It should:
— Consider the statistical plans and
draw to the attention of Parliament and Ministers any imbalance
or inadequacies.
— Keep under review strategic developments
for the statistical system.
— Monitor, through whatever methods
it deems necessary including independent audits, the professional
integrity of the whole statistical system and adherence of statistical
producers with the Code of Practice.
— Assure itself that the statistical
system takes account of the needs of all users.
— Monitor the performance of the National
Statistician in the discharge of his/her functions.
— Advise the National Statistician,
Parliament and Ministers as appropriate.
17. Members of the Board should be non-executive
and of the highest calibre.
18. If the ONS is to be seen as independent
of Ministers it would send a powerful signal if the appointments
of the Chair and the National Statistician were made by the Queen
on the joint recommendation of the Prime Minister and leaders
of opposition parties and first Ministers in devolved administrations.
ENSURING THE
QUALITY AND
INTEGRITY OF
NATIONAL STATISTICS
19. The combination of a system of governance
based on the broader public interest, including a Statistics Board
of the kind we have suggested and a clear legal framework for
the National Statistician and the ONS, should go a long way towards
meeting the requirements for quality and integrity.
20. We also consider that a statutory code
of practice designed to restore trust is needed. This code needs
to alter the balance between those things that are the responsibility
of statisticians and those things that are the responsibility
of politicians and policy officials.
21. A good example is reform of the current
release arrangements for statistics. These could be changed without
legislation but a statutory code would place any changes on a
much securer footing. The existing non-statutory arrangements
have not improved matters six years after the launch of National
Statistics.
22. It is essential that data collected
for statistical purposes should only be used for statistical purposes
(statistical analyses and outputs and related uses such as maintaining
sampling frames). The responses from individuals or businesses
should be kept confidential and access restricted only to those
legitimately involved in statistical production. The only exception
to this should be the release of Census records to the Public
Records Office 100 years after the Census is taken.
23. There is one important matter in which
the Government's proposals are extremely inadequate. Countries
throughout the world are making more and more use of information
contained in administrative systems for statistical purposes.
This has many benefits such as improving the efficiency of the
statistical system and allowing statistical estimates at finer
levels of detail than surveys will often allow. The ONS and other
parts of the statistical system should have access to administrative
records for statistical purposes with the condition that any records
so accessed will be afforded the same level of confidentiality
protection as for the survey responses from individuals and businesses.
WINDING UP
THE STATISTICS
COMMISSION
24. If a Statistics Board along the lines
we have proposed is established, then we consider that the Statistics
Commission can be wound up. The Governing Board as proposed by
the Government is an executive body and therefore if that model
is pursued there will still be a need for a body like the Statistics
Commission to oversee the Governing Board.
THE DEFINITION
OF NATIONAL
STATISTICS
25. National Statistics should include all
statistics produced by Government (including its agencies and
privatised functions) that are released for public consumption.
At the very least it should cover those statistics on which the
public and Government rely to make decisions and judgements about
policy and the effectiveness of Government and public services.
26. Under a new model with a Statistics
Board, that body will be well placed both to call for gaps to
be filled and to support the National Statistician in refusing
to accredit inadequate statistics.
27. In the current system it was assumed
that over time Ministers would wish to include more statistical
outputs as National Statistics. This has not been borne out over
the last five years. If decisions about scope are left with Ministers
(as intended in the Government's proposals) we are likely still
to have patchy coverage (based on the views of individual Ministers
rather than the significance of the information to public debate)
and official statistics which inform only those aspects of an
issue that the Government considers important. As proposed, Ministers
are, in effect, being given the job of deciding whether the legislation
should apply to them and their Department's statistical work.
THE APPARENTLY
LOW LEVELS
OF PUBLIC
TRUST IN
OFFICIAL STATISTICS
28. Public trust in statistics is low and
we believe it is possible to improve matters. Legislation is no
panacea and public trust in statistics is inevitably bound up
with other issues of trust across the public realm. Good statistical
legislation is a necessary but not sufficient criterion for improvement.
The behaviours of people within and outside the statistical system
will be just as important. By acting soon on things that can be
done without legislation, such as release practices, the Government
could signal its intent quite powerfully. Specifically we believe
that all National Statistics produced in policy departments should
be released through a National Statistics Press Office physically
separated from any policy department with a dedicated staff of
Press Officers whose function is to facilitate the release and
explanation of the statistics. Press Officers in policy departments
would be free to explain government policy and offer the Minister's
comments on the policy implications of the statistical release.
No-one outside the statistical production team should have access
to the statistics until they are released to all.
THE ROLE
OF STATISTICIANS
WORKING OUTSIDE
ONS IN CENTRAL
GOVERNMENT AND
THE DEVOLVED
ADMINISTRATIONS
29. The Government's proposals in respect
of statistics produced outside of ONS are extremely weak even
though this is where many of the concerns about the current statistical
arrangements are centred. Our proposals contained in the earlier
sections of this response greatly strengthen the Government's
proposals and bring the statistical production outside ONS into
the mainstream of the arrangements.
30. Heads of Profession for statistics in
official agencies that produce National Statistics outside ONS
have two facets of their role and the combination of the two is
particularly challenging. They must produce statistics for public
consumption, and in doing so must contribute to and uphold the
goals of quality and integrity in statistics. At the same time
they must support the statistical needs of the department in developing
and monitoring policy. These two roles need to be separately recognised.
In respect of the former they must be seen to have a overriding
professional responsibility to the National Statistician. In the
latter they must ensure that Departmental needs are met using
the highest professional statistical standards. At one time the
Head of Profession would often be at Director General level in
a government department. This does not happen at all now, indeed
the role is often one, two or more levels below Director General,
in many cases not even within the Senior Civil Service. Given
the fact that the role of Head of Profession has been so weakened
the professional line to the National Statistician needs to be
strengthened in order for Heads of Profession to operate effectively.
31. Nonetheless, the Government Statistical
Service has played an important part in initiatives such as integrating
analysis across government and more recently the Professional
Skills in Government agenda. It is possible for a distinctive
identity for professional statisticians to be maintained whilst
working closely with colleagues in other related professions.
Stronger leadership would help the GSS become more influential,
to the benefit of both government and the wider community.
32. It was hoped at the outset that UK statistics
would not be jeopardised by devolution. This has not been borne
out in practice. Nor does the system as a whole support the legitimate
needs of users in devolved territories by providing consistent,
comparable statistics across the UK. There is an urgent need to
engage the devolved administrations in recognising the failures
of the present arrangements both in producing consistent, coherent
UK statistics and in providing consistent statistics that allow
each of the devolved administrations to compare itself to other
components of the UK.
33. An important additional factor is that
statistical groups in Policy Departments do not have the critical
mass to sustain certain crucial specialisms. It is essential that
the ONS has a support role to these groups and is funded at a
level that will allow these specialisms to be deployed in support
of the entire system.
LESSONS TO
BE LEARNT
FROM OTHER
COUNTRIES' LEGISLATIVE
FRAMEWORKS FOR
INDEPENDENCE FOR
STATISTICS
34. Whilst there are important differences,
notably the federal nature of the arrangements in those countries,
the most obvious comparators are probably Canada and Australia.
These countries are good comparators because of the shared Parliamentary
model and because of the worldwide reputation that their statistical
offices have.
35. It has been said that comparisons with
these countries are flawed because the UK system is decentralised
whilst the Canadian and Australian systems are centralised. It
is true that there is a stronger decentralised element of the
statistical system in the UK but in fact, since the creation of
ONS, coverage of the central statistical agencies is reasonably
similar. Moreover, there is some convergence insofar as in the
UK we are seeking to improve the role of the centre in supporting
the integrity of the whole system whilst both Canada and Australia
are seeking to improve the cross government coordination function
to ensure that administrative and management information are more
effectively used to create National Statistics. An example of
this is the approach taken to coordination of crime statistics
in Australia where serious issues of public confidence arose in
the 1980s and have been tackled through coordination mechanisms
involving the Australian Bureau of Statistics and police authorities.
36. Essential features of good practice
in the approaches of other countries are:
1. The statutory authority of the National
Statistician and National Statistical Office, including for impartiality
of presentation, objectivity of method and assurance of confidentiality
to respondents.
2. The statutory function of the National
Statistician to coordinate across the statistical system.
3. Statutory access by the National Statistical
Office to administrative records across government for statistical
purposes.
37. It should be noted that the UK already
has obligations under European Law and on account of membership
of the International Monetary Fund in relation to statistical
independence.
May 2006
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