Race Disparity Audit: Government, Equality and Human Rights Commission and Office for National Statistics responses to the Committee’s Third Report of Session

Appendix 1: Response from the Government

I am writing to provide you with the Government response to the Committee’s report of the Inquiry into the Race Disparity Audit (Annex A).

I would like to thank the Committee for their work on this inquiry. It is encouraging that the Committee has recognised the Race Disparity Audit as an exemplary programme for tackling injustices. I am grateful for their constructive suggestions for how the Government can now go further to ensure we meet the ambitious commitment made by the Prime Minister when she announced the Audit and build a fairer society which works for everyone.

I am pleased to be able to respond positively to the committee’s recommendations with regards to improving the collection and availability of data by ethnicity. To make Ethnicity Facts and Figures more useful for researchers, NGOs and other users, the Race Disparity Unit have already taken action to provide a ‘dashboard’ to indicate progress for updating and adding new data, alongside adding additional non-governmental data to the site. To standardise the use of ethnicity classifications across Government, the Race Disparity Unit will work with Departments to support the collection of survey data with more detailed breakdowns of ethnic groups, and with ONS to explore the practicalities of changing administrative systems. To improve the quality and robustness of ethnicity data, the Race Disparity Unit will produce a Quality Improvement Plan, and work with the ONS Centre of Expertise for Inequality as it takes forward the results of its audit of inequality data.

The Government is committed to taking action on the issues identified by the Race Disparity Audit and the Prime Minister has made a specific commitment to ‘explain or change’ ethnic disparities. The Government is already taking a coordinated and strategic approach, led by the Race Disparity Unit in Cabinet Office, and overseen by myself as Chair of the Inter Ministerial Group.. I stand by the view I gave the Committee in February that there is no magic to putting the label of “cross-Government strategy” on something. Updating of measures on the Ethnicity Facts and Figures website will generate time series data about those measures and transparency about whether key indicators are improving or deteriorating over time, allowing the Government to be held to account for progress addressing the issues highlighted by the Audit.

I am grateful to the Committee for their suggestions, and look forward to continued dialogue on how we can go further to build a fairer society which works for everyone.

Rt Hon David Lidington CBE MP

Annex A: Government response

The Cabinet Office should publish a schedule for the addition of new data sets to the website and planned updates to the data already held on the site. We recommend that particular efforts are put into ensuring that data sets are robust enough to be comparable, including over time, and that regional variations can be seen. In future, the Government should consider including non-governmental sources of data in this resource. (para 17)

The Government agrees with this recommendation. The Race Disparity Unit (RDU) has recently added to the website a ‘dashboard’ which indicates progress with new measure pages and with updating existing measure pages, and is planning to develop this into a publication schedule. The RDA will also publish information about the full stocktake of ethnicity-related datasets from the 2016 Audit exercise.

When the Ethnicity Facts and Figures website was launched, in October 2017, it included data from central Government Departments only. Subsequently, in response to user demand, data (about first year entrants onto undergraduate and postgraduate degrees) from the Higher Education Statistics Agency (HESA) have been added, and the RDU anticipate adding more non-governmental data where there is interest from users and where it is confident about the quality of the data.

As the RDU develops the current suite of new measures during 2018-19, and further new data, it will continue to prioritise according to data quality and user need , and it will publish time series data and geographical comparisons where the data are sufficiently robust.

The Government, led by the Cabinet Office, should adopt the same categories as are used in the Census as the minimum standard for data collection on ethnicity across Government departments, and work with individual departments to ensure that this happens in all official data sets and administrative data in the public services for which they are responsible. At present this means using the ‘18+1’ categories, but should the categories change for the 2021 Census, the Cabinet Office should take advice on how best to ensure comparability of data sets over time. (para 25)

The Government strongly supports the intention of this recommendation, though it is mindful of practical considerations.

There are important elements of governance and leadership in implementing this recommendation. ONS is responsible for the design of the Census, including advising Parliament on the format of a question about ethnicity. It also has a leadership role across the Government Statistical Service, to encourage those conducting household surveys to use survey questions and output classifications that are harmonised with the Census approach, and across government more generally in relation to the use of harmonised approaches (to data collection) on administrative systems.

The Cabinet Office will consider with ONS how to support the widespread adoption of the detailed (‘18+1’) Census ethnicity classification, and any consequent changes to take account of the 2021 Census.

The Ethnicity Facts and Figures website includes data drawn from social surveys conducted by or on behalf of government (such as ONS’ Labour Force Survey and MHCLG’s English Housing Survey), and administrative data systems as diverse as benefit receipt, national curriculum assessments, and mental health service provision.

The sample sizes of most household surveys are too small to produce reliable estimates for detailed (‘18+1’) ethnic groups for a single year, and so outputs are typically at an aggregated level (such as ‘5+1’). However, the potential offered by data linkage and by (for example) combining survey data for several years in order to produce a larger sample that can be analysed at the ‘18+1’ level suggests that there would be value in more detailed data collection. Given that Departments currently collect ethnicity data in many different ways, the RDU will continue its work with Departments to enhance the consistency of ethnic classifications of data collected and include on the website.

For administrative sources, such as transactional databases, the cost of change might be significant. The RDU will work with the ONS to explore the practicality of changing each relevant system alongside the likely utility of the data. However, it may be more straightforward and cost-effective (in some cases) to use the provisions of the Digital Economy Act 2017 to link data sources in order to add an ethnicity marker to the administrative data source.

The Equality and Human Rights Commission and the Office for National Statistics should work together to provide updated guidance for public bodies, service providers and employers on how to collect consistent ethnicity data and how public sector bodies should use that data to assess their compliance with the Public Sector Equality Duty. (para 26)

The RDA understands that ONS is responding separately on this recommendation, and will seek to work with the EHRC and ONS, offering advice based on its stakeholder engagement.

We recommend that the Government publish an action plan to improve the consistency and robustness of the data it collects on the basis of ethnicity, to be implemented within 12 months. In the longer term, the Government should ensure that key data can be disaggregated to allow factors such as gender, age, region, socioeconomic status and religion and belief to be taken into account alongside race and ethnicity. (para 33)

The Government agrees with this recommendation. The RDA will produce a Quality Improvement Plan, and will continue to work closely with ONS’ new Centre of Expertise for Inequality as it takes forward the results of its audit of inequality data.

The key features of the Quality Improvement Plan will include work to:

Continue to add to the downloadable data files (that form part of each measure) information classified to the harmonised “5+1” categorisation, where more granular data are shown in the measure - this will help provide a common currency for analysts wishing to compare data across topics (though it is recognised that each of the five broad ethnic groups are likely to mask different experiences and outcomes for component sub-groups)
Increase the consistency of data, as a result of the harmonisation of sources.
Increase data robustness, by combining data for a few years, to enable better estimates for smaller ethnic minority groups; by exploring what steps might be taken to reduce levels of non-reporting; and by exploring the feasibility of ‘ethnic minority boosts’ of existing surveys.
Increase the geographical granularity of the data, by exploring the potential of data held by local authorities and local public service delivery organisations and third sector partners.
Produce new analytical resources, by combining (linking) existing data sets. As the RDU develops updated and new measures on the website it will explore the potential to add factors such as gender, age, region, socio-economic status,recognising that many of the existing measures include at least some such analysis. The RDU will explore with users the extent to which they are interested in analysis by religion.
In order to enable us to hold Government to account in defeating ethnic injustice, we recommend that a cross-government race equality strategy be developed. This strategy should formalise the role of the Cabinet Office and the inter-ministerial group in enforcement, co-ordination and oversight of Government departmental plans to close the disparities revealed in the Audit. The strategy should:
be developed by departments alongside the Cabinet Office;
bring together and examine the ‘explain or change’ analyses and conduct oversight of the actions of individual departments’ plans;
identify actions that cut across more than one government department, and ensure that mechanisms exist for departments working together on their implementation; and
set out indicators of progress for each 12-month period, with quarterly progress reports required from individual departments. (para 43)

In response to the Audit, the Government has already announced action to tackle ethnic disparities in the criminal justice system, through DWP challenge areas, through reviews of school exclusions and the Mental Health Act and through support for the

£90m Big Lottery Fund aimed at tackling youth announcement. Further announcements and actions will be made over time as further analysis and policies develop.

The Inter Ministerial Group on Race Disparity oversees and monitors the Government’s programme of work to tackle ethnic disparities, including regular reports from individual Departments.

Updating of measures on the Ethnicity Facts and Figures website will generate time series data about those measures and transparency about whether key indicators are improving or deteriorating over time.

The inter-ministerial group has the potential to provide the kind of high-level oversight that is needed, but its work needs to be informed by subject-specialist input on data collection and analysis and on race equality. We recommend that the Office for National Statistics be invited to attend the inter-ministerial group as observers to provide advice to the group. (para 44)

The RDU supports the Inter Ministerial Group and has a close and effective working relationship with the ONS, which helps to inform the advice the Group receives. Future consideration by the IMG of data/analytical issues, such as about further harmonisation of ethnicity data, will be discussed with ONS to ensure that advice to the IMG reflects ONS’ strategic leadership across the Government Statistical Service.

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Published: 11 September 2018