Scotland 2022 census: Office for Statistics Regulation assessment

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Earlier this year, the Office for Statistics Regulation (OSR) carried out an assessment of Scotland’s 2022 census, which will allow the regulator to recommend whether the Census outputs should be designated as National Statistics when first released.

As part of the OSR assessment, we submitted a detailed response setting out our concerns about the conduct of the National Records of Scotland (NRS) and Scottish Government in relation to the sex question. Our response looked at the development of the question, as well as the appeal hearing in the judicial review brought by Fair Play For Women against the Registrar General and the Scottish Ministers and the arguments put forward in court by the Scottish Government.

We argued that because of the approach taken by the Scottish Government, the key demographic variable of sex – the item of data most used from census outputs – will be unstable in Scotland’s census, conflating two different demographic concepts to an unknowable degree. This also means that the data will not be directly comparable to data on sex in the other UK censuses, nor will it be suitable for equality monitoring purposes. We concluded that the conduct of the Scottish Government in relation to the census was likely to breach a range of the principles set out in the Code of Practice for Statistics. Our full response can be accessed here.

In June 2022 we wrote to the OSR, to put on record our concerns about the defensive lines used by both the Cabinet Secretary for the Constitution, External Affairs and Culture, Angus Robertson, and Registrar General, Paul Lowe, in relation to the low response rate to Scotland’s census. We stated that, based on public-facing communications, we were not confident that the Scottish Government fully appreciated the gravity of the shortfall in responses, and more specifically the implications for addressing inequality. Our letter can be accessed here.

We have also submitted our response to the the OSR assessment and follow-up letter to the Scottish Parliament Constitution, Europe, External Affairs and Culture Committee Inquiry into Scotland’s Census.

We note that a letter from the OSR to the NRS published today raises further concerns about transparency and trustworthiness in relation to how the NRS is ensuring good quality census estimates:

…given the range of challenge that has been evident over recent months, we consider that it would be in NRS’s interests to be more transparent now about the steps that it is taking to generate good quality census estimates. We consider that being transparent about the various current activities, plans, processes etc would assure users of NRS’s trustworthiness and reassure users that they can confidently expect high quality estimates from the 2022 census. Various practices within the Code of Practice1 reinforce this need for openness even ahead of the release of the statistics. Demonstrating this trustworthiness is especially vital given the importance of census estimates.

Mark Pont (OSR) to Pete Whitehouse (NRS): Scottish Population Census, 17 August 2022

The letter notes that the NRS has established an International Steering Group to advise it in relation to this year’s census. It has so far declined to publish the minutes of meetings of this group, so how the Group is scoping the task and what actions it has recommended remain to be seen. We hope the inquiry by the Constitution, Europe, External Affairs and Culture Committee will shed more light on how the Group was set up, how its membership was chosen and how its business is being conducted.

The Committee’s inquiry offers an opportunity more generally for transparent, thorough scrutiny of the NRS’s conduct of the 2022 census in Scotland. We hope full advantage will be taken of that.

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