Memorandum from the Statistics Commission
1. This paper describes how the Statistics
Commission fits into the new National Statistics arrangements.
It goes on to describe how the Commission is approaching its task,
both in terms of the organisation/ways of working and of the strategic
approach, and to set out the emerging shape of its work programme.
National Statistics' framework
2. Framework for National Statistics,
published in June 2000, set out the role and responsibilities
of the Statistics Commission:
"2.2 The Statistics Commission is independent
of both Ministers and the producers of National Statistics. It
has its own budget and is able to commission its own activities;
the Chancellor, as Minister for National Statistics appoints the
chairman and members in accordance with the Code of Practice published
by the Commissioner for Public Appointments. The Commission produces
an annual report, to be laid before Parliament by the Minister
for National Statistics. It advises on the quality assurance and
priority setting for National Statistics and on the procedures
designed to deliver statistical integrity. It advises Ministers
of areas of widespread concern about the quality of official statistics,
so that Ministers can take these considerations into account in
determining priorities and making decisions about National Statistics."
Status, finance and reporting arrangement for
the Statistics Commission
3. The Commission is an independent, non-statutory,
advisory non-departmental public body (NDPB). It obtains its grant-in-aid
funding from HM Treasury, although it does not have crown status.
(Grant-in-aid funding confers a degree of financial and thus operational
independence beyond that normally enjoyed by advisory NDPBs.)
It is independent of both ministers and the producers of National
Statistics, and is supported by a small secretariat.
4. Framework for National Statistics
requires the Commission to "review the need for statistical
legislation after two years and report back to the Minister for
National Statistics, and keep the legislative framework under
review thereafter". This review will cover the wider legislative
framework within which ONS and National Statistics currently operate,
as well as the status of the Commission itself.
5. A financial memorandum and management
statement, together with the National Statistics framework, set
out the broad framework within which the Commission will operate.
These were initially drawn up by the Treasury, in its role as
sponsor department, and are currently being reviewed in consultation
with the Commission. The National Audit Office will audit the
Commission's annual accounts, and plans to conduct a dry-run audit
for this year's accounts to the end of December 2000 early in
6. The Commission will produce an annual
report to be laid before Parliament by the Minister for National
Statistics. This will comment on the annual report of the National
Statistician and on the way the Commission has fulfilled its remit.
Subject to final decisions on timing, bearing in mind this requirement
to comment on the National Statistician's report on its own, the
Commission intends to publish a report and accounts in respect
of its first (part) year of existence, ie the financial year to
31 March 2001 in summer 2001.
7. As a new body we are still developing
our organisation and ways of working but this section sets out
our current approach and how we see that evolving in the near
8. Current budget is £1.35 million.
In the first year over half of this is being spent on set up costs
relating mainly to accommodation but also to internal IT systems
and setting up our website. In 2001-02, our first full year, the
balance will change with staffing and related costs and externally
commissioned research and audit work likely to account for the
great majority of spend.
9. The Chairman and the seven commissioners
are part time. The Commission's formal meetings have a key role
in giving a corporate and strategic steer to the work but after
the initial period they will be relatively infrequent as we do
not see them as the only or indeed the main mechanism by which
individual commissioners will contribute their experience and
expertise to taking the business forward.
10. So far the Commission has met formally
twice (in September and October) and plans to meet at end November
and subsequently every other month. This has been supplemented
by two informal meetings of commissioners over the summer to share
initial ideas and information. Other activities undertaken or
in train include:
a variety of representational and
information exchanging meetings including the chairman addressing
the Royal Statistical Society and attending a pre-Monetary Policy
meeting the National Statistician
(who attended part of the October meeting) to discuss his plans;
examining a National Statistics quality
review report to help inform discussions about how we should deal
with these in future;
visits to main ONS data collection
sites to improve our understanding of how National Statistics
face to face meetings and phone discussions
with the secretariat to help develop work programme proposals.
11. Currently the Commission has a staff
of four with arrangements in hand to recruit a fifth. Although
our budget would allow for recruitment of slightly more staff
we have decided that at least initially, and probably in the longer
term, we would prefer to retain some of this budget to use on
commissioning research and audit projects from outside experts
rather than trying to recruit in a small audit team expertise
in all the areas we might wish to examine. This should also allow
us to make use of recognized experts in any particular field who
are more likely to be available for specific projects. The five
posts are as follows:
Chief Executive: Accounting Officer
and responsible for overall management of the team including development
of the work programme. Currently taking the lead role within the
team in developing links with stakeholders.
PA to the Chief Executive: the post
holder also acts as secretary to the Chairman on Commission business
liaising with his other office and will become "Webmaster"
once development work on our new website is completed.
Head of Secretariat and Resources:
Secretary to the Commission and currently mainly involved in activities
relating to the set up of the office. Once this has been completed
the post holder is likely to take a lead role in supporting the
Commission in its consideration of broader and less technical
issues such as reviewing the need for statistical legsilation.
Statistical Audit and Research Manager:
currently being recruited and will have a dual role. We are looking
for someone who can commission and manage audit and research projects
but who can also undertake some statistical audit and scoping
work personally. This flexibility will be important as to allow
us to achieve the appropriate balance between internal and external
conduct of our work.
Secretariat Administrator: currently
provides support to Head of Secretariat and also works with the
Chief Executive's PA on general office administration and enquiries.
This post is currently filled on a temporary basis as our long-term
needs are not yet clear.
The first three posts were filled by secondment
from Government departments but the Statistical Audit and Research
Manager is being recruited by open competition.
Transparency and openness
12. Framework for National Statistics
says that the Commission "will operate in a transparent
way with the minutes of its meetings, correspondence and evidence
it receives, and advice it gives, all normally being publicly
available for scrutiny." The Commission is taking a proactive
approach here. All Commission meeting papers and minutes will
be placed on the website once it has been extended to facilitate
this and in the meantime we are offering to e-mail the minutes
on request. We are also preparing an overall openness policy and
considering the best means of allowing easy access to correspondence
and other material.
13. Our core task is to advise on the quality,
quality assurance and priority setting for National Statistics,
and on the procedures designed to deliver statistical integrity,
to help ensure National Statistics are trustworthy and responsive
to public needs. While this remit is in many ways an indivisible
one we have found it helpful in considering how we should discharge
it to identify three broadly distinct but associated characteristics
of National Statistics:
These are discussed below and will be constant
themes running through our work programme for 2000-01 and future
14. In preparing our work programme we are
aware of a very large number of issues to be tackled and the need
to prioritise. Our first objectives are outlined in paragraphs
21-29 below. Contributions from the Commission must be thoroughly
researched and considered if they are to be effective and we will
need to resist responding without due study and consideration
to topical issues just because they are topical. We see our role
in all three areas as checking that National Statistics has proper
processes in place and that they are delivering the required outcomes.
We cannot and should not do their quality assurance or user consultation
for them and any perceptions that we were doing so would risk
undermining their work. At the same time we have been conscious
of the need to take account of stakeholders' perspectives and
also to move quickly onto substantive work. Projects need to be
of value in their own right but we will also be looking to draw
general points from specific pieces of work.
15. We will take this programme forward
in a way which makes best use of the fact that we are a small
but flexible organisation, relying on others to do most of the
detailed work and basing our strength ultimately on the considerable
powers of openness.
16. We have used the term integrity in a
fairly narrow sense of independence and freedom from interference.
To some extent our role here is essentially keeping and being
seen to keep a watchful eye and responding if and when things
go wrong. We believe however it is important that we should be
seen to be alert in this area and with this in mind we have explicitly
asked the National Statistician to notify us should he be directed
by a minister on a professional matter.
17. We are very much aware of the opportunity
which will be presented by the forthcoming consultation on the
new National Statistics Code of Practice. We will be looking carefully
at the whole new Code and taking a particular interest in the
integrity and release practice aspects.
18. We are also conscious that perceptions
of integrity play a key part in determining public confidence
in National Statistics and we will be addressing this latter issue
in the context of our work to build links with stakeholders.
19. In looking at the quality of National
Statistics we are concerned with fitness for purpose. It is important
to get the numbers right (as well as collecting the right numbers)
but no set of statistics is likely to be 100 per cent accurate.
What matters is that the data should be good enough to meet users
main needs and that their limitations should be understood and
communicated. Quality issues will be the main focus of the "audit"
and related projects in our work programme although some projects
will have a user responsiveness or communications aspect too.
There are also two related generic issues which will make important
calls on our attention in the coming months. As the new procedures
for National Statistics Quality Reviews are developed we will
need to address two questions:
How should we influence the priorities
for these reviews?
How can we comment on the reports
of the completed reviews in a way which will add real value to
We do not know the answer to either of these
questions yet but will be giving high priority to addressing them
over the coming months.
20. Our role on this third aspect involves
checking that National Statistics takes proper account of the
full range of its users' needs. While we cannot and should not
conduct the National Statistician's detailed consultations for
him we regard this as a key area on which we need to be well informed.
Some of our proposed audit projects (for example the one concerned
with the adequacy of National Statistics to monitor the Government's
National Cancer Plan) include an element of this and we will be
looking at the developing National Statistics consultation process
itself, but the main focus of our work in the user areas this
year will be as a key part of a wider project to develop links
with identified National Statistics stakeholders.
21. Although much of our work is defined
by the developmental and general approach described earlier we
will also be setting in hand some more specific projects. Preliminary
work on these will be undertaken by the Commission itself and
its secretariat, seeking appropriate factual input from National
Statistics, but we will explore various ways of working and intend
to outsource some of the work to independent experts (such as
academic methodologists or subject specialists) in due course.
22. Our initial programme will not attempt
to set out a firm timetable for this work but rather to indicate
what we plan to do and where appropriate in what order. We intend
to initiate work on all the projects discussed below within the
financial year 2000-01 but timetables for completion will depend
on the outcome of initial scoping work and on decisions on relative
priorities made as our plans develop.
23. In our first year or so of operation
however, we also need to concern ourselves with the infrastructure,
both physical and conceptual, in which we are working. Issues
here range from the simple practical ones of setting up and equipping
the Commission's offices to ensuring we set in hand any necessary
preparatory fact finding to support our specific remit to advise
on the need for statistical legislation in due course.
"Audit" and related projects
24. As well as commenting on the National
Statistics processes we also have a remit to carry out spot checks
and if necessary carry out or commission our own audits. We have
identified two areas to which we are giving priority to examining
the extent to which National Statistics
assesses and communicates information about the reliability of
the adequacy of National Statistics
to monitor the Government's National Cancer Plan.
We see these projects as having value in their
own right but also as being complementary to each other and having
the potential to allow us to draw out general points. We will
be considering the rest of our work programme at the next meeting
and strong candidates for a second tranche of work are:
a review of a methodological topic
such as the use of seasonal adjustment;
a review of the quality of regional
a check on progress with implmentation
of the Review of the Revision of the Average Earnings Index.
We will however continue to plan flexibly in
the early stages to allow for our priorities to be refined in
the light of our developing links with users and other stakeholders.
Building links with stakeholders
25. The White Paper Building trust in
statistics envisaged that the government would ask the Commission
to "recommend to Ministers . . . its own machinery for covering
the interests of users and producers of National Statistics .
. .". While we have not received such a formal request we
have taken up the spirit of this and extended our interpretation
of it slightly to cover all three main groups of stakeholders:
users of National Statistics, producers of National Statistics
and providers on raw data on which National Statistics are based.
We believe that we need to understand the perspectives of all
three groups in order to fulfil our remit properly and we recognise
that these three broad groupings are far from homogeneous (this
point is discussed further as regards users below) and there are
some individuals and organisations which belong to more than one
of the classes. For example individual businesses and local authorities
may be both users and providers and some statisticians within
government who are both users and producers. There are also a
number of key stakeholders, ranging from professional bodies such
as the Royal Statistical Society to Parliament itself, who combine
a user role with a broader one.
26. Our general approach to this area is
less structured and more informal than might be implied by the
term "machinery". We are open minded about the appropriate
arrangements in the long term but felt it was right initially
to build informal links in a flexible way. The rest of this section
discuss our approach to building links with users where we have
mainly focused our efforts so far but we plan to take a similar
approach to building links with producers and providers and have
already established some links with producers.
27. We are conscious that some good links
between users and producers of National Statistics exist and that
work is in hand following Framework for National Statistics to
develop these further. We are seeking more information about these
which form part of the context within which we need to develop
our own links for two main purposes:
understand the perspectives of these
more specifically to allow us the
check on or "audit" whether National Statistics consultation
arrangements are working properly.
We are not trying to duplicate National Statistics
consultation arrangementsas well as this being inefficient
there would also be a risk that confusion about roles might undermine
28. There are also a number of well-established
statistics user groups dealing with different areas such as business
statistics or health statistics brought together under the Statistics
User Council (SUC) umbrella and we have seen establishing links
with these as important.
29. Users of National Statistics are however
more diverse than reference solely to these expert users outside
government would imply. It is still an oversimplification (for
example not addressing the particular interests of the substantial
number of local government users of National Statistics) to indentify
three main classes of users:
users within government;
expert and specialist users outside
general users: members of the public
whether as voters or as users of public services.
Because of the diversity of the user community
we will need correspondingly diverse and flexible approaches but
have not yet formed a view on wheter we should be aiming in due
course for a single formal mechanism supplemented by informal
links or a multiplicity of communication channels. The SUC conference
on 9 November (at which the Chairman will be speaking) provides
an opportunity to take further soundings of expert users but we
are also conscious that we have more work to do over the next
few months to develop our understanding both of current user concerns
and of how we can sensibly tap into and supplement existing structureswhich
are themselves changing. Formal consultation about longer-term
arrangements may be appropriate. One aspect we know we need to
address but with which we have not yet made much progress, is
the needs of general users who are unlikely to participate in
user groups and an issue closely related to thisthat of
assessing public confidence in National Statistics.
30. The Statistics Commission has established
a physical and practical infrastructure and the commissioners'
early meetings have clarified our strategic approach and sense
of direction. In the coming months increasing our visibility and
consolidating the work we have already begun on building links
with stakeholders will be vital but we will also to make a start
with substantive "audit" projects as well as commenting
on the draft National Statistics Code of Practice. In doing so
we will need to be responsive to the views of stakeholders and
to be prepared to evolve flexibly as we better understand their