Category Archives: Meeting notes

Fraud, error & debt | 26 June 2014 | Meeting note

26 June 2014

Attendees

Oliver Butler, Law Commission
John McIlwraith, DWP
Jonathan Dennis, DWP (Legal)
Mitch Riviere, HMRC
Sarah Wells, HMRC
Alison Morris, CLG
Bevis Ingram, Local Government Association
Geoff Eales, Charities Commission
Graeme Thomson, Cabinet Office
Rupert Cryer, Cabinet Office
Simon Burton, Cabinet Office
Jonathan Wallis, Cabinet Office
Dan Nesbitt, Big Brother Watch
John Elliot, Open Rights Group
Judith Jones, ICO
Ben Hayes, Statewatch
Javier Ruiz, Open Rights Group
Paul Arnold, Cabinet Office 

Morning Session

Item 1 – Arrival and Welcome

  1. The session opened with a welcome and an overview of the context of the current Open Policy Making (OPM) process for this workstrand.
  1. Introductions around the table were made. 

Item 2 – Review Previous Minute and Actions

  1. A minor edit to the minutes was agreed.
  1. The action points from the last meeting were reviewed:
1 Paper B to be edited as per group discussion and re-circulated for agreement.
2 John Wallis (economics, CO) and PA to meet with CO Behavioural Insights team to examine options for stakeholder studies on fraud and information sharing. CO have reached out to the BI team but due to workloads no progress has been made as yet. CO expect to have met by the time of the next FED session.
3 Any further queries on Paper C should be directed to PA in the first instance. No further comments were received.
4 Any further queries on Paper D should be directed to PA in the first instance. No further comments were received.

Item 3 – Paper B: ‘Fraud Error and Debt – Heads of Agreement’

  1. The latest version of the paper was put to the group. It was agreed that the paper accurately reflected the position the group had reached to date.
  1. PA summarised the major areas where the group felt more clarity was needed.
  1. It was noted that the Law Commission were continuing work around data sharing between public bodies.
  1. A discussion around the differences and overlaps between data-sharing and data-matching took place.

Item 4 – Paper D: ‘Current thinking on Debt’

  1. Rupert Cryer gave a talk on the scale of government debt, the base case for tackling it and the contribution that a general information sharing power could bring to that.
  1. A full discussion followed that. The following points and queries came up:
  • Do we need to make existing gateways more effective (there are currently at least 15) – or do we need new legislation? It seems that at least some of the solution involves using what we have already but better.
  • Private sector examples: HSBC, Barclays, Thames Water. Seem to show results from pooling data from numerous areas of a business into one collection team and process. Queries around if this is truly analogous to public sector debt, especially when 90% is in DWP and HMRC.
  • Collectibility of debt. What do we know about the composition behind the headline debt figures? How aged is the debt? How collectible is it realistically?
  • What is the realistic size of the prize?
  • Is the expectation towards a) sharing data on the citizen – or b) sharing data on the debts?
  • The Ministerial lead is that we should be aiming to manage debt across Government Departments and agencies better. Multiple debts should be administered as one.
  • Infrastructure – what would follow from the additional data sharing? How would it be used, collated, monitored? What is the expectation of who would do this?
  • Are we envisaging a one-stop debt collection agency?
  • What role if any for the private sector? Concerns around that. The civil society groups probably have more faith in Government than the private sector to run such undertakings.
  • Point made that the private sector is already involved in public sector debt collection.
  • Is the problem more at the front end of data collection – i.e. data not being properly collected and cleansed in the first instance, leading to poor and inaccurate records.
  • Where is the evidence to show that greater or better data sharing would help with debt collection?
  • Advantages of a single point of debt collection – to Government and the citizen – were broadly acknowledged by the group.
  • DWP & HMRC own 90% of debt. Need more on the composition of this debt.
  • DWP & HMRC have a gateway. Indications are that it operates effectively. What would a new power bring to these departments data sharing activities?
  • What is the privacy impact – and how will it be measured?
  • How many multiple debtors are there out there – we cannot currently see. The unknown unknowns. Is a pilot the first step to size up the issue?
  • What are the current frustrations to debt collection? We need evidence on this.
  • Is it a process issue? Cultural?
  • Is access to RTI data being considered? We know how collection agencies already use this data to time their collections.
  • There was a feeling from some that there was a gap between the problem statement and the evidence so far presented.
  • Definitions: are they tight enough? What is “overdue debt”? Goes towards what is collectible and what is written off and how it is accounted for. What is the composition of the headline debt figure?
  • Child Maintenance was mentioned – is this a government debt? It is not owed to government presumably.
  1. In summary, whilst the group felt clear on the questions for further research there was a feeling that further work needed to be done on the scope of the problem and what the expectation around collectibility would be. A 22% rule of thumb percentage was discussed.

Afternoon Session

Item 5 – Paper D: ‘Fraud, Error and Debt Gap Analysis’

  1. The group broke into three smaller groups for further discussions on paper D. The content of Paper D was agreed. The groups were then asked to try and identify any additional evidential gaps. The following was fed back to the entire group:
  • National Audit Office 1% public sector fraud tolerance level – is it too ambitious?
  • What are the cultural reasons for poor data sharing?
  • What are the likely data sharing flows that could increase as a result of a general power?
  • What are the disincentives for sharing? Risk of making mistakes? Sanctions against individuals?
  • Is the issue a result of lack of clarity around current data sharing powers?
  • To what extent does a solution involve engineering of what we currently have?
  • How do we account for non-monetary fraud (e.g. Blue Badge)?
  • Is government ambitious enough in chasing fraud?
  • Who will Government need to engage with to implement a solution?

Item 6 – ‘Evidence Gathering – Options and Success Criteria’

  1. The small groups then reconvened to discuss the framework and success criteria for further evidence gathering. The evidence gathering process needed to:
  • Be robust
  • Be clear on what its methods and measures are from outset.
  • Be framed in accordance with relevant best practice.
  • Be transparent.
  • Draw on statistically significant source material.
  • Take account of previous research.
  • Take account of the current landscape.
  • Contribute to our recommendations.
  • Understand the comparative value of various data sets.
  • Take appropriate account of foreign jurisdictions.
  • Take appropriate account of the private sector’s experience.

Recap of Progress and Actions

  1. The discussions would continue at the all day session on 18th July 2014 at the BIS conference suite, 1 Victoria Street.

De-identified data for research | 13 June 2014 | Meeting note

Friday 13th June, 1pm-14:45pm

Attendees

Daniele Bega HMRC
Marcus Besley BIS (Go-Science)
Frances Pottier BIS
Ben Humberstone ONS
Johanna Hutchinson BIS
James Denman CLG
Jackie Riley HMRC
Maria Sigala ESRC
Amanda Smith Open Data Institute
Nicky Tarry DWP
Olivia Varley-Winter Royal Statistical Society
Tammy-Jo Johnson ONS
Iain Bourne ICO
Pete Lawrence Cabinet Office
Simon Whitworth UK Statistics Authority
Melanie Wright Administrative Data Service, University of Essex
Nagina Akram DWP
Sue Holloway Pro Bono Economics
Dan Nesbitt Big Brother Watch
Cindy Bell HMRC
Rufus Rottenberg Cabinet Office

Meeting note

  1. Sam Smith, who was not present, tabled a question.
SAM SMITH’S QUESTION CABINET OFFICE ANSWER NOW PROVIDED
For approved projects matching identifiable data from multiple data holding departments, where could that research be conducted? If the matching share was relying on the proposed legislation for its vires, then the answer is that that research would have to be conducted in an Accredited ADRC Safe Haven (However the title for this role is still be debated so the name for this role may change in due course).
ie a project using, for example, HMRC and DWP data, which both departments hold part in their own safe settings (so it’s not new data We would challenge this assumption. In a TTP share as data is always matched between two or more datasets, essentially the matched data is a new dataset because though its consitutuent parts are already known the combination of them in a de-identified form is new.
, and there are already processes in place for approval), would that project be possible? Yes, the project would be possible and it could adopt the existing standards as an additional part of the proposed TTP share under the new legislation. However because the nature of TTP shares are set up so that no one body ever has access to all the information involved, then if say HMRC and DWP were taking part then neither of them could be the Accredited ADRC Safe Haven   for that share (but they could potentially be so for some other share that they were not supplying the data for) So the HMRC safe setting could be accredited as an Accredited Safe Haven if HMRC was handling the linking of the DWP data to e.g. MOJ. 

 

Could there be cross-accreditation of settings, so projects approved by both boards could have data in the highest security setting, whichever department that is?I appreciate this isn’t a simple question that starts to cut across departmental silos.  We are not setting rigid security settings or share agreement terms as a part of the legislation, so each share can have whatever level of security it is deemed necessary for the particular data and circumstances of each case. Such shares can adopt a higher standard as suggested, where this would be necessary and proportionate. The accreditation would provide a certain minimum, but there is flexibility in each share to go beyond this as a part of the standard data share agreement negotiating process between the data controllers.
If you’re going to try and change the law, it would seem worthwhile to discuss things that might be useful that you can’t currently do and there is a clear need for. This new power fulfils that condition, because although sharing by two public authorities of de-identified data through a safe haven is permissible in some cases and by some bodies, not all bodies can use this process for all data/cases. Additionally how each body does it varies from body to body, and case to case.
Legislation that lets you do stuff you already do means you’re either acting illegally or it’s substantively pointless There is a need because, as set out above, public authorities cannot always do it. There is also substantive benefit in changing the law to provide a more transparent, more consistent method available to all public authorities.
  1. Cabinet Office has arranged an all day meeting at Admiralty House on 23rd July for the ONS strand and de-indentified strand together. It is hoped that, following this, policy strand documents establishing areas of agreement whilst identifying unresolved issues and setting out possible solutions can be agreed.
  1. HMRC explained their rationale for a new proposal for legislation that would provide specific powers for HMRC. The ambition is for these powers to be contained in separate clauses in a data sharing bill. The power would permit HMRC to make anonymised individual level information available for non-tax purposes. Currently research projects that require access to information held by HMRC must demonstrate a benefit to HMRC’s functions. HMRC would, using this specific power be able to share this information, for example with other government departments and researchers through the HMRC Datalab. There will be safeguards and it would be sensible to try to keep these in common with those being developed across the data sharing proposals.
  1. Discussion of the draft discussion document on the how a general power for two or more public authorities to share de-identified data for research purposes would work. ONLY if they wished to use this particular power, which would be additional to any existing powers, public authorities would have to use an Indexer approach, under which source public authorities would provide de-identified data to an “Accredited Trusted Third Party Safe Haven” [CO comment: despite what was said in the meeting, this seems a clearer way of describing an organisation when it is the beneficiary of a particular data share under the power] and provide identity data stripped of all payload information to the Indexer, thus allowing data to be linked while ensuring that when this power is used, no one party ever has access to all the identifiable and all of the payload data. The Firewall Centre model works similarly, but the Indexer and the Accredited Trusted Third Party Safe Haven are within the same legal entity but separated by firewalled sections. If public authorities already posses the vires, they will not need to use this power.
  2. Accreditation of TTP safe havens, accredited Indexers, accredited research projects and accredited researchers would be the responsibility of an overarching authority, specifically provided for in legislation. The document proposed certain minimum criteria for these. The glossary required improvement and group members were asked to propose definitions for consideration. There was a discussion around attempting to ensure consistency with ICO code of practice and concepts in the DPA. [CO comment: the purpose of this glossary is to illustrate effectively the circumstances covered by the proposed legislative provisions and this will take priority in defining the terms over and above any requirement for the definitions to match any other existing definitions]
  3. Attendees were asked to suggest which public authorities the power should not apply to. It was intended that NHS bodies should be excluded from this power.
  4. “Identifiers” would not be definitively listed.
  5. The words “Administrative Data Research Centre” should not appear in the legislation. Most data provided to the ADRC will do so under existing powers, and not using the new powers.
  6. The security accreditation model design should look at the entire system in the first instance. Separate accreditation for centres and researchers is appropriate but if they are not consistent and joined up mitigation against risks cannot be managed.
  7. There needs to be ongoing communication between the parts of the system to ensure they are working properly. This requirement will be for guidance. Clarity would be needed around disclosure control and reasonable likelihood of identification.
  8. ONS were concerned that any legislation should not “contradict” the Statistics and Registration Act. There would be discussion between ONS and CO lawyers.
  9. Clarification of terms such as aggregated, individual level, record level, de-identified, unidentified, anonymised was necessary.
  10. Holding of metadata, re-use and release processes should probably not be mandated in law as it already exists in the UK Statistics Authority code of practice.
  11. The requirement that research be “published” would be satisfied by the legal definition of publication – not peer review journal publication.
  12. Additional criteria for accreditation would be set by the relevant safe haven.

Fraud, error & debt | 4 June 2014 | Meeting note

4th June 14:00 – 16:00

Attendees

Amanda Hillman, DWP
John McIlwraith, DWP
Jonathan Dennis, DWP (Legal)
Mitch Riviere, HMRC
Paul Wilson, NHS Protect
Sean Rigney, MoJ
Emily Meredith, DVLA
Alison Morris, CLG
David Williamson, London Borough of Tower Hamlets
Tony Qayum, London Borough of Tower Hamlets
Bevis Ingram, Local Government Association
Kevin Campbell-Scott, Southwark London Borough Council
Geoff Eales, Charity Commission
Rupert Cryer, Cabinet Office
Simon Burton, Cabinet Office
Jonathan Wallis, Cabinet Office
Alistair Webb, Chiltern District Council
Dan Nesbitt, Big Brother Watch
Javier Ruiz, Open Rights Group

Minute

Item 1 – Review of Last Minutes and Actions

  1. The session opened with a welcome and an overview of the context of the current Open Policy Making (OPM) process for this workstrand.
  1. The minutes from the last meeting (9th May) were agreed.
  1. In light of comments from the plenary meeting around diary management, dates of 26th June and 23rd July were suggested for the next two meetings. The 23rd July meeting could be a full day meeting if there is interest in doing that.
  1. A request was made for venues alternative to Government owned venues as it is felt that using neutral space is more in accordance with the ethos of the Open policy approach.

Item 2 – Paper B: ‘Heads of Agreement’

See: http://datasharing.org.uk/latest/fraud-error-and-debt-strand-heads-of-agreement-and-areas-for-further-work/ 

  1. In groups, Paper B was discussed.
  1. Conclusions were shared. Broadly it was agreed that the Paper accurately reflected the current state of agreement within the group.
  1. Amendments to be made to the document, to be made by PA and circulated, were agreed.

Item 3 – Paper C: ‘Current Government Thinking’

See: http://datasharing.org.uk/current-proposals/

  1. Following on from the actions point agreed at the last meeting, CO shared some excerpts from the original policy paper on inter-government data sharing. It was stressed that the intention was to not colour the open policy process by having the CO paper as something to ‘work to’ but instead the Paper was provided for information and to contribute to the ongoing Open Policy discussion.

Item 4 – Paper D: ‘Base Case For Debt’ 

  1. Rupert Cryer gave a talk setting out the scale of government debt and base case for chasing it. Questions and discussion followed afterwards. Queries were raised around the extent to which this represents an information sharing problem.
  1. It was agreed that obtaining further information on the possible role that greater information sharing could play in recoverability of debt should follow.

Item 5 – Actions/next steps

1 Paper B to be edited as per group discussion and re-circulated for agreement. PA
2 John Wallis (economics, CO) and PA to meet with CO Behavioural Insights team to examine options for stakeholder studies on fraud and information sharing JWPA
3 Any further queries on Paper C should be directed to PA in the first instance. PA
4 Any further queries on Paper D should be directed to PA in the first instance. PA

 

Plenary meeting | 29 May 2014 | Meeting note

Royal Statistical Society, 12 Errol Street, London, EC1Y 8LX
29th May 2014

Attendees

tbc

Introduction

–        Welcome by Simon Burall (Involve) and summary of the process so far, and what it aims to achieve.

–        Simon outlined that the Cabinet Office ideally wants civil society to come up with concrete proposals to ensure that data sharing has the appropriate safeguards. However, this process is not a juggernaut to data sharing. It may be that we don’t agree on the circumstances where it should be done and how. If this is the case, it will be a good outcome to identify where disagreement lies.

–        Peter Lawrence (Cabinet Office) outlined the three different strands of activity: Research and statistics (ONS and de-identified data for research; Fraud error and debt; Identifiable data to improve services for individuals.

–        He outlined the timeline of the process and the key milestones anticipated along the way. These include a draft policy proposal paper, signed off by government and civil society by mid September, a White Paper before Christmas, then a period of wider consultation until the end of March 2015. He stressed the commitment of Francis Maude to the process.

Updates from strands

Each of the three strands gave brief updates on the work that they had been undertaking.

ONS strand (research and statistics)

–        The ONS is seeking easier, speedier and more flexible access to de-identified administrative data, so it can reuse it for statistical purposes only. They have been undertaking workshops with CSOs and moving forward with departments who own the data, privacy and impact assessments around sharing the data. One of the issues is that the process for approving data sharing currently requires affirmative resolution in both houses, and there is a concern that this is not an effective use of parliamentary time – and an effort to find a more effective alternative system. This involves not only the ONS but the whole of government statistical services.

–        The difficulty that academics have in getting access to administrative data. There are legal barriers for some departments to sharing data, and the effort to find a common approach and apply standards with greater consistency. The problem of civil society participation and the need for greater engagement was highlighted.

Fraud, error and debt

–        The challenge is for this group to agree a proportionate way of using data sharing to address fraud, error and debt issues. There has been strong engagement but a challenge of continuity of participants.

–        There are a range of estimates on the scale of the problem from different bodies, ranging from £47 – 68 billion. There is a greater need for clarity on the sources of these figures.

–        Data sharing happens already, but the process is cumbersome and can involve numerous bilateral bodies.

–        Public attitudes to data sharing are segmented, with younger people more at ease. There is frustration when information isn’t shared across public bodies in what the public perceive as ‘the same’ problem. The need for more systematic approach to gauging public opinion, using more rigorous methodologies.

–        Many of the issues from fraud error and debt strand have been around what the evidence base was for the need to increase data sharing; whether the existing gateway system is adequate and detailed evidence on how the system works. There was a request for clearer policy papers on where this stands.

Tailored public services for individuals

–        This strand involves using shared data to tailor public services.

–        Particular application might be on the unemployment and skills agenda for local authorities. David Coleman explained the potential applications for his work in Southend Borough Council. A single data sharing process would reduce the need for separate data sharing agreements between departments.

–        There have been discussions about what other kinds of services could be tailored – particularly for carers, vulnerable people and older people. There is a question of scope and where best to draw lines.

Small group work

Participants were asked to break into three groups, one for each strand, and answer:

–        Where is there currently consensus?

–        Where is there disagreement?

–        What would a useful next step be?

The three groups then reported back to plenary

Fraud, error and debt

–        There is agreement that there’s an issue with fraud, error and debt that should be tackled.

–        There is disagreement on whether data sharing is the answer. There is a need to gather more evidence on levels of fraud, error and debt, and for more systematic pilot studies on the effectiveness of data sharing.

–        The next steps is to go back to original proposals of Cabinet Office to see where government thinks it might want to get to, and then to think more about what types of information might need to be shared. Is it just financial information, or designatory information (e.g. names and addresses) etc.

–        Need to explore what kind of evidence is required for firm decisions to be taken.

Research and statistics

–        There is a shared commitment to explore whether a ‘gold standard’ for data sharing safeguards might exist.

–        There is agreement that de-identified data is less of an issue. Have to make sure that what is a new power doesn’t weaken everything else that exists regarding safeguards

–        There is disagreement on questions of scope, and how far to enlarge the reach of the safeguards.

–        Next step is to share work and develop the safeguards (with way of looking back to see the proposal is better than what we have already).

Tailored public services for individuals

–        There was agreement that it wasn’t good practice that each time a new problem arises it is necessary to go to parliament to develop a new gateway.

–        Agreement that there is a need to streamline the process of data sharing, and that this should be some kind of generic process (not necessarily a gateway).

–        Agreement that parliament doesn’t necessarily provide optimum scrutiny and there may be stronger and more appropriate alternatives.

–        Need to know what the purposes for which this generic processes should be used (there is currently disagreement on this). Then once know the purpose, the next step will be to look at powers and then move on to safeguards.

–        Need more information on how existing gateways are created, where are the hurdles, and what ‘powers’ means in a practical sense.

Conclusions

Simon Burall identified common themes between the groups:

–        The concern with how to future proof proposals

–        How to make it flexible enough to be used for future events but not too vague.

–        The need for pilots. How might we pilot and test proposals, and what would the pilot need to tell us to generate confidence to move forward?

–        There are a number of issues that aren’t related to safeguards or evidence but to wider political issues. For example the role of the private sector. This is a part of the conversation that also needs to be brought out.

Problems and solutions

In small groups, participants identified problems and solutions with the process so far. These were then reported back in plenary:

–        Lack of a forecast schedule of meetings there’s a continuity problem with attendees.

–        Very London centric.

–        Need for a pre-pack of information so everyone can be on the same page when arrive.

–        Make it a longer day (a full day) to maximise value of travel.

–        Output should we summarise what we came up with we can share the evolution of process with our colleagues and communities.

–        Leave more time between meetings so people have the opportunity to assimilate materials.

–        An agreement at end of each meeting that we won’t go over again at that meeting. A ground rule that don’t go over old ground.

–        Some sort of template that demonstrates where we’ve got to – an agreed premise of what that strand was trying to do. A clear way to managing it – template that people could comment on, and that would set out where the next level of question is.

–        Meetings too short and ambitious, too unwieldy. Solution is better structures to meetings and clearer objectives to meetings.

–        Larger meetings, roving microphones.

–        Make use of online methods, live streaming? Clear that we could do this but important that this has an audience and isn’t into the ether.

–        For next session helpful to deep dive on one theme and work through and process the barriers rather than being so broad.

–        Civil society not fully represented. Not much spectrum of understanding. Who can be the link people to translate the data people to the nuts and bolts people? Participants were asked to link us to people who should be invited to participate.

–        Need to open up to all different perspectives – not just all one type of people. Need people in the policy areas who aren’t data people but whose issues will be affected by data.

–        Private sector gap.

–        Question of what the end point necessarily is? What is a white paper? Should this be assumed?

–        The need for more frequent outputs and involve other orgs – blog on datasharing.org.uk site. Only one public document on datasharing.org.uk

–        Datasharing.org.uk presumes the destination where we are going to get to.

–        Need for consultation on the format of the day.

Conclusion

Simon Burall summarised the discussion. He reflected the need for a longer, all day meeting with more preparation up front, greater clarity on the objective and what comes out at the end. He summarised the desire for the Cabinet Office to communicate more clearly before and after meetings.

He noted the caution of sensitivities around private sector participants, alongside the need to ensure this group was appropriately involved at the right stage. He appealed for participants to inform himself and Tim Hughes of people who should be invited into the room.

De-identified data for research | 15 May 2014 | Meeting note

Thursday 15 May 2014, 10:00-12:00

Attendees

Melanie Wright – University of Essex
Marcus Besley – BIS
Frances Pottier – BIS
Vanessa Cuthill – ESRC
Tanvi Desai – University of Essex
Tracey Gyatang – NPC
Johanna Hutchinson – BIS
David Knight –DoH
James Denman  – CLG
Maria Sigala – ESRC
Nicky Tarry – DWP
Edgar Whitley – LSE
Steve Bond – ONS
Simon Meats  -CO
Naqina Akram – DWP
Olivia Varney-Winter – RSS
Oliver Butler – Law Commission
Melanie Wright – ADS
Steve Pavis – ADRC Scotland
David Ford – ADRC Wale
Rufus Rottenberg – CO
Peter Elias – ESRC
Peter Lawrence – CO
Iain Bourne – ICO
Peter Elias – University of Warwick
Daniele Bega – HMRC
Jackie Riley – HMRC

Meeting note

  1. Welcome and introductions

Previously provided – rationale for legislation

There was a discussion about the proposed purpose of the legislation. This was to create a single common approach that all public bodies who wish to share data for research purposes can adopt with set standards that all can easily apply and work through consistently with certainty. This should not only benefit the public bodies who will now be able to more consistently, safely and easily share such data, but crucially it is preferable for the public as well because, rather than a varying landscape of uncertainty of who can do what with what, there will be a single, consistent clear, transparent and tested/overseen system that can be verified, scrutinised and understood by all. At the same time the other existing powers and methods of sharing data will continue to exist and be capable of use.

  1. There followed three presentations regarding the rationale for legislation; these covered the academic perspective, government perspective and the third sector perspective.

Government perspective

Three issues 1. Why we need it 2. Why we need more, better, faster, more flexible 3. Why we need it to be more accessible outside government

  • We have seen the benefits of use of admin data and data linking (both admin to admin data and admin to survey data). – what we do now only gets us so far
  • Society is becoming more dynamic, faster moving so policy development and evaluation needs to be faster and more joined up
  • Joined up government policy needs data linking for government, academia and third sector
  • Open data agenda – we want & need innovations from outside government.
  • Big Data – Public sector data uses catching up with private sector?
  • Efficiency and effectiveness of policy development, for individuals, society and the economy
  • International competitiveness – we can’t afford to react later than competitor countries – a 2 year disadvantage cannot be acceptable.
  • Need to move from what often became a default “No, not yet, too complicated, very risky, will take ages to work out” to a default “Yes, within sensible limits laid down by DPA and HRA”
  • Complex legislation beyond DPA and HRA. Statutory departments like HMRC have no powers to share data unless explicitly stated in legislation. Others have varying legislation that prohibits or permits data sharing. There are often explicit gateways which states what data can be shared with what organisation for what purpose. This has affected departments’ abilities to use common law powers. This leaves highly complex arrangements that differ between departments and can be unclear whether a new sharing proposal meets existing legislative frameworks.
  • Need to get greater consistency between Departments to support clarity, confidence, efficiency and focus on privacy issues that would matter to the data subject. We need to share more de-identified data to respect their interests and address concerns. Best impact, best value.
  1. The Administrative Data Liaison Service gave a presentation entitled: Why greater sharing of de-identified data is desirable – an academic perspective.

Please see attached document: Legal barriers to and benefits of access to administrative data: Initial summary of responses to an email survey initiated by the ESRC funded Administrative Data Liaison Service.

  1. A representative of the Third Sector then spoke about two examples of where data sharing would have been beneficial to the NPC data lab. These are summarised in the attached case study paper.
  1. There was then an opportunity for questions.

Q. Are we saying there are things that we cannot currently do, when in fact we can currently do them but with great difficulty?

A. It is true that some data sharing can and does take place under current legislation; however this happens under dozens of different gateways. It is slow, inefficient and unwieldy. It is also open to interpretation and has led to lengthy, complex and costly legal negotiations and debates.

Q. This legislation would solve the legal barriers but is the greater barrier a cultural one?

A. Yes, this may well be true. However this legislation is the first step towards changing the culture. We recognise that we need up to date efficient research, we have evidence that current legislation does not permit that. We appreciate that changing the culture surrounding data sharing will take time to change we believe that a transparent legislative process with agreed governance will kick start this change.

Q. So is legislation in order to ‘nudge’ cultural change appropriate?

A. Whilst we hope that legislation does lead to a cultural change, the legislation is being proposed predominantly to facilitate up to date and efficient research that is able to respond to a fast changing world.

7.     A presentation by the ADRN on Governance and Transparency.

Initial procedures papers will be available at the end of May 2014.

There will be a UK Statistics Authority led governance board. They have held one meeting and a second is booked for early June. The board will oversee all ADRN activities. They will ratify all proposals and procedures.

All perspective ADRC users will have to be accredited. The full details of the accreditation process will be available in early June. Applications will be made to an Independent Approvals Panel. The panel will be formed of individuals who are independent of the ADRN. They will be an expert disinterested body. It is anticipated that this panel will meet ‘virtually’ on a monthly basis and face to face on a quarterly basis. Therefore, applicants will receive the outcome of their application in a timely manner. The ADRN will provide advice to researchers on preparing a report for the panel. Requirements will be laid out in full but are expected to include the need for applicants to:

  • be affiliated with an RCUK approved institution;
  • be a fit and proper person;
  • be able to carry out the research independently, or under the supervision of an appropriate supervisor;
  • have a clear understanding and approach to privacy;
  • undertake an agreed training programme (to include legal access, legal sanctions, disclosure control and manual output scrutiny)

Their project must:

  • have passed through an ethical review process;
  • have demonstrable public benefit;
  • not be related to any operational government function;
  • be feasible;
  • have sufficient scientific merit;
  • not be able to be carried out in any other way.

All research outputs must be made accessible in the public domain. Researchers must inform the ADRN of the publication and/or presentation of any research. Copies of the documentation, any code and/or syntax used must be made available to the ADRN. In addition, researchers must submit a summary of research in accessible language (maximum two pages) on completion.

Following consideration the panel can accept, reject or request further clarification on the proposal. There will be an appeals procedure for rejected proposals to the Board of the ADRN. The data holder can decline to provide the data at any time, regardless of the panel decision.

The ADRN will publish information on all researchers, project proposals and datasets used.

There is some uncertainly about the numbers of applications that are anticipated. ESRC have reviewed applications for current data labs and secure environments for early modelling. They have prepared an option analysis and strategies for the various application scale possibilities; including slow start with a sharp increase, and a high early uptake. It is speculated that there may be some pent up demand that may create an early peak. ESRC will also programme research activities that make use of the resources.

8. A presentation on Handling of data – TTP and security, Please see document: An example of an existing data linkage model: The case of the Farr Institute @ Scotland.

A presentation about the key features of Secure Anonymised Information Linkage (SAIL) in Wales. They have 320 individual data suppliers and have completed over 250 projects to date.

9. The ADRN gave some further information regarding training for prospective researchers. The training would be compulsory and would be delivered face to face. It aims to establish a culture of responsibility and confidentiality. It will provide education on the legal frameworks. Personal responsibility and disclosure control. Pilot training will be rolled out during the test period.

Following training the researcher will be required to sign a legal service agreement and a confidentiality agreement. These are counter signed by their Institution. There will be a variety of sanctions and penalties that will be taken if there are any breaches of these agreements. The policy is currently under development and is based upon the UK Data Secure Lab policy. ESRC can withhold funding from both individual and the institution. They can also ban both the individual and/or the institution from future research.

10. Group work

A) Do you agree with rationale for the proposal?

Those present agreed with the rationale as a means of achieving a level playing field in terms of vires to share de-identified data. The following reasons were given:

  • researchers currently don’t have a good understanding of what gateways are available;
  • the legislation supersedes lots of ‘bits’ of legislation that currently exist;
  • the current odds and ends of legislation approach lack transparency;
  • there are serious inefficiencies in the current process;

Two doubts were:

  • If the legislation was only used for ‘nudging’ attitudes then it was disproportionate; however a response to this criticism was that cultural change may result from the legislation, but its principal purpose was to create a level playing field, which was a proportionate use of legislation
  • Unsure how well the research strand sits with the other two strands

B) What are the risks?

  • Proposals are not the “cure all” and do not solve issues of budgets, culture and organisational resistance – but they may help the cultural issue.
  • Withdrawal of funding from the ADRC network.
  • Confusion in media around terms such as identified/de-identified/pseudonymised/disclosure control
  • Repeat of the problems around care.data

C) Are the safeguards appropriate?

Suggested safeguards for exploration and discussion

  • What options are there for independent external scrutiny, including independent security analysis and accreditation of the safe havens – or is UKSA the only body that can accredit the safe havens?;
  • communication of the safeguards to the public is key, vagueness leads to mistrust;
  • commercial companies can be partners but they will never see the data;
  • we must be clear that the safe havens never sell data;
  • we must be clear about exactly what purposes data will and will not be used for;
  • prioritise transparency.
  • In order to avoid confusion with care.data, data from NHS organisations should be excluded from the power – access for researchers to health data will be from the Health and Social Care Information Centre
  • explore whether Trusted Third Parties Indexers should be public sector organisations only – this might reduce fear that the data would be mishandled.
  • in the messaging around the proposal there would need to be a justification as to why individuals were not given the opportunity to “opt out” of having their data shared, given that such an opt out was made available for health data held by GPs in care.data. In response to this, it was pointed out that there are existing gateways for data to be shared, where is no opt out. In addition, the data that is the subject of these proposals would not be able to leave the safe haven.

11. Due to time restriction it was requested that any further points or questions e made via correspondence.

12. Rufus proposed that the next stage of the process be carried out by correspondence. The next meeting on de-identified data will be at 70 Whitehall on Friday 13 June 13.00-15.00.

ONS | 9 May 2014 | Meeting note

Attendees

Ben Humberstone -ONS
James Edmonds – ONS
Tammy-Jo Jonson – ONS
Oliver Butler – Law Commission
John McIlwraith – DWP
Rufus Rottenberg – CO
Simon Meats – CO
Mitch Riviere – HMRC
Mike Hughes – National Statistics Advisory Group, RSS
David Kane – NCVO
Sarah Rolin – ICO
Naqina Arkan – DWP
William Elwarn – HMRC
Tracey Gyateng – NPC
Sonia Bussy – Involve
James Denman – DCLG
Peter Lawrence – CO

Minutes

  1. Welcome by Rufus Rottenberg and summary of the outcomes of the previous meeting.
  2. James and Tammy-Jo presented the current Information Sharing Order process and identified the areas that would change under new legislation. A digest of the debates on the orders had previously been circulated. This demonstrated the variable level of Parliamentary scrutiny on the information sharing orders.
  • What does the parliamentary process add?
  • What should we replace it with?
  1. Small group work to address questions.
1. What are the risks?
Public perceptions of leaks, loss of data, data getting into wrong hands

Fears of administrative use

ONS getting lots of data without adequate governance

Threat to response rate of census and surveys if trust is reduced

Loss of parliamentary scrutiny

Loss of reputation if business cases are not designed to meet parliamentary scrutiny

Media perception of data ‘free for all’

Speculative data shares; would there be more ‘fishing expeditions’?

 

 2. Possible ideas for safeguards
Consistency with the prohibition on disclosure

Appropriate systems i.e. stand alone computers and restricted staff

More clarity around the legal safeguards that currently exist

Full parliamentary scrutiny of proposed legislation that would give ONS these new powers

Transparency, i.e. publish all PIAs and business cases on the ONS website for all data shares

ICO providing continuing scrutiny

Information assurance processes, panels, systems and accreditation in place

Information Asset Owners personally responsible and accountable for data

Publicity for business cases and give two weeks for comments to be fed in from the public

ICO has already produced data sharing code of practice

ICO conducts audits, but focuses on those organisations where they feel they will have the biggest impact.

Accreditation process for researchers

A non-statutory panel (like the ADRN approval panel) appointed by ONS/UKSA containing some external members to report annually on the ethics and public benefit of the data accessed by ONS under the new powers. This report to be published by ONS.

  1. The next meeting is booked for Friday 23rd May. We discussed whether this meeting was required. Rufus will work with Involve to discuss production of a document that all members can comment up. This may be undertaken by correspondence. Rufus will confirm whether the meeting will go ahead.
  1. Actions
Action By whom
Send information regarding the Information Assurance process to Rufus Tammy-Jo Johnson
Send information regarding the accredited researcher application process to Rufus Tammy-Jo Johnson
Work with Involve to discuss the next steps Rufus Rottenberg

Fraud, error & debt | 9 May 2014 | Meeting note

Attendees

Sonia Bussu, Involve
Jackie Rley, HMRC
Bevis Ingram, LGA
Oliver Butler, Law Commission
Paul Warren, Informatica
Tony Qayum, LB Tower Hamlets
Jonathan Dennis, DWP (Legal)
Mike Pinder, LB Southwark
Paul Wilson, NHS Protect
Ivana Bartoletti, NHS Protect
John Eliott, Open Rights Group
John McIlinwrath, DWP
Sara Rolin, ICO
Weiran Ni, Cabinet Office (Analysis and Insight)
Javier Ruiz, Open Rights Group
David Williamson, LB Tower Hamlets
Nick Jones, HMRC

Apologies from:

Paul Arnold, Cabinet Office
Simon Burton, Cabinet Office
Emma Carr, Big Brother Watch
Sam Smith, Independent Consultant

Minute

Item 1 – Introduction

  1. The session opened with a welcome and an overview of the context of the current Open Policy Making (OPM) process for this workstrand.

Item 2 – Ground Rules

  1. The ground rules agreed at the last session were circulated. Particular attention was drawn to the adoption of Chatham House Rules.

Item 3 – Presentations from Present Government Department and Agencies

  1. Following on from the actions point agreed at the last meeting, present government departments and agencies were invited to give a short summary presentation on their own current information sharing powers and any difficulties encountered in using them.
  1. Representatives of HMRC and DWP spoke to the group in turn setting out broadly what information sharing powers they had available and what limitations were encountered in using them.

Item 4 – Group Discussions

  1. Participants divided into three smaller groups to discuss: 

5.1.  Why the current arrangements are not working?

5.2.  To what extent this is a data sharing problem?; and

5.3.  Where are the barriers to effective sharing?

  1. Following these discussions, the group reconvened to share thoughts. In the course of discussion the view was expressed that it was not clear from the evidence that current arrangements were not working properly and that there was a real demonstrable need for a more general permissive data sharing power. it was suggested that other factors such as risk-averse working cultures – may be significant.
  1. In order for the group to move its deliberations forward, it was felt that this aspect needed to be addressed in more detail. Requests were made to see more of the underlying evidence and case studies driving the policy.

Item 5 – Actions/next steps

 

1 Evidence (1) – The estimated extent

 

Request for CO to bring more detailed evidence of the problem to the group.

 

30 May 2014

 

Cabinet Office Fraud Error and Debt team

2 Evidence (2) – Where would data sharing help?

 

Request from CO to provide more work on what the projected impact on FED would be of increased data sharing. What realistically is the ‘size of the prize’?   Case studies would be particularly helpful.

 

 

30 May 2014

 

Government departments represented and Local authorities

3 Future meeting dates

 

CO to release dates of new meetings well in advance to allow participants to coordinate diaries

ASAP

 

Cabinet Office

 

  1. It was felt that the proposed date of the next meeting was not suitable as May 22 is polling day for EP and LA elections, and therefore some invitees will be unavailable. Therefore a new date, time and venue will be announced by CO.

Fraud, error, & debt | 30 Apr 2014 | Meeting note

30th April 10:00 – 12:00

Attendees

Paul Arnold, Cabinet Office (DSPT)
Simon Burton Cabinet Office (FED)
Jonathan Bamford, Information Commissioner’s Office
Reuben Binns, Southampton University
Jonathan Dennis, DWP Legal
Sonia Bussu, Involve
Tim Hughes, Involve
John Viggers, DWP
Emma Carr, Big Brother Watch
Ivana Bartoletti, NHS Protect
Nick Jones, HMRC (RIS)
Edgar Whitley, LSE
John Elliott, Open Rights Group
Sam Smith, Independent Consultant
Simon Meats, Cabinet Office
Mitch Riviere, HMRC
Graeme Thomson, Cabinet Office (FED)

Minute

Item 1 – Introduction

1.     The session opened with welcome and an overview of the context of the current Open Policy Making (OPM) process for this workstrand.

2.     Note: Despite travel difficulties arising from the on-going tube strike, a substantial proportion of invitees were able to attend this workshop. The team were very grateful for this turnout, particularly from those who travelled some distance to be present.

Item 2 – Ground Rules

3.     Each participant was invited to contribute a suggested ground rule for the session. It was agreed that these would be brought to each session for reference.

Item 3 – Presentation

4.     The Cabinet Office gave a presentation: “The story behind data sharing to protect public money from fraud”.

5.     Amongst other points, it was emphasised that the preferred approach was  to prevent fraud occurring rather than detect it once it had taken place; a substantial proportion of detected and proven fraud was unrecoverable as a result of the amounts being either spent or moved abroad.

6.     The presentation was interspersed with questions from the group. Some concerns were expressed about the tone and diction used, for example the term “fraudster” was felt to be neither helpful nor accurate, and that much of what was termed “fraud” was unintentional or opportunistic rather than organised and deliberate. Further, when referring to “de-identified” data it was important to be accurate as to the level or technique of de-identification employed: “anonymisation”, “pseudonymisation.”

Item 4 – Group Discussions

7.     Participants divided into two small groups to discuss:

7.1.   Whether it could be agreed that there was an issue with fraud, error and debt in the public sector;

7.2.  Whether an extension of data sharing powers could help and how; and

7.3.   What key areas needed to be explored further by the group through the Open Policy process?

8.     In summary, it was agreed that:

8.1.  There was an issue with fraud and debt.  There may be an issue with error in the public sector;

8.2.  Data sharing may have some impact on this set of issues; and

8.3.  There were a range of options, not purely legislative, that could alleviate the issue.

9.     It was also agreed that further work is required in clarifying and defining the underlying issues before possible solutions can be explored. The underlying issues include the following:

Clarifying the issue

  • Is the level of fraud actually unacceptable?  What is the ’bite point’ at which it becomes unacceptably high?
  • How do we measure fraud in the public sector?  How reliable is the available data?
  • What is the ‘size of the prize’, that is, what is the potential saving?
  • Would further data sharing powers provide better quality insight into the nature and extent of the problem and possible solutions?
  • The need to be mindful of cost-benefit: likely outcomes vs. costs (both financial and privacy).
  • What evidence needs gathering to ensure the group are as informed as possible?
  • The need for policy to based on clear empirical evidence.  A recognition that the issue is politically charged and brings risks of an overly emotive response.

Current data sharing powers

  • The need to map out the current data sharing landscape.
  • Are current powers actually adequate?
  • Are they used fully?  If not why not and can this be improved?
  • Would a more general power risk a circumvention of prospective data sharers having to properly justify the basis for sharing?

Legislative options and the alternatives

  • Is legislation really the best option?
  • For example, what about improved training and guidance to improve the use of existing powers?
  • Could impact assessment(s) be prepared for the non-legislative alternatives?

Miscellaneous

  • Is a pilot scheme possible?  Could it be used to obtain better data on the issue?
  • The issue of meaningful consent: the importance of it being explicit and freely given.
  • what would be the Framework for preparing impact assessments?
  • Whether fraud and debt should be contained within the same Open Policy stream.
  • The likely roll-out of any legislative solution: 2 years to become law plus 6 months to bring into operation was mooted. This should be balanced with the current situation where each data sharing proposal  can take up to 2 years

Item 5 – Actions/next steps

1 Preparation of summary outline of current data sharing powers.  An overview of how they are used and what the perceived limitations are. All represented government departments and agencies.Report back on 9 May.

 

2 To invite the Analysis team to discuss measurement of the possible impacts of improved data sharing powers on fraud levels and the privacy of the individual. Paul Arnold to invite and report back on 9 May.
3 An overview of alternative options to a legislative solution Sam Smith to provide a perspective for the close of the 9 May session.
3 To invite a local government representative for the next session. Paul Arnold by 9 May.
4 To have prepared a note of this meeting for circulation to the group and potentially posting on the data sharing web site. Jonathan Dennis to send to Paul Arnold by 2 May.
5 To provide a note that starts to answer some of the points for clarification for discussion at the next meeting. Graeme Thomson for circulation prior to 9 May.

The next meeting will take place at the Royal Statistical Society from 14:00 to 16:00 on 9th May 2014.

De-identified data for research | 24 Apr 2014 | Meeting note

Introduction

This is a meeting note of the first meeting of the de-identified data for research strand.

The Workshop agreed:

  • the ground rules set out in the document circulated at the meeting; and
  • the success criteria set out in the briefing document, as amended by the workshop of 23 April, which were described by Rufus Rottenberg (Cabinet Office).

It was noted that in this case the definition of “personal data” includes data about businesses. It was also important to remember that there were issues around the sensitivities of data relating to deceased persons which is not covered by the Data Protection Act.

Action: Rufus Rottenberg to circulate the amended ground rules and success criteria.

Background and context

Professor Peter Elias, from the Economic and Social Research Council (ESRC), explained the background to the proposals covering access to de-identified data for research and statistics. He covered the history of the development of the Administrative Data Research Network (ADRN), and the emerging proposals for clear governance arrangements, which would involve  a governing board chaired by UK Statistics Authority (UKSA) (who report directly to Parliament)  with the involvement of the Information Commissioner’s Office (ICO) in an advisory  capacity.

In discussion, the following points were made by the group:

Public understanding of what academic research is and how it might use Government data is not very clear. It needs to be clarified so that people understand better what the implications are.

The lessons of Care.gov need to be learned and applied in this case.

Communication has to be very good indeed and carefully crafted.

  • The public availability of the outcome of research, in accessible language, is an essential element in trust and transparency, including where the research proved nugatory.
  • UKSA position about preventing reuse for operational purposes has to be made clear in relation to these proposals, given its projected role relating to the ADRN.

Academia is increasingly entrepreneurial – the “public body” status of universities does not apply in the way it did so in previous decades –  and therefore the public’s acceptability and perceptions of this shift and its implications for the ADRN is particularly important.

Local authorities are also part of the public sector.

Protection from re-identification is an essential concern,  with reference to the “mosaic effect”, etc.  There was also some discussion about avoiding confusion about de-identification techniques and terms – “anonymisation,” “pseudonymisation” etc

There might be scope to build on the long tradition of protecting identity in data used for research that exists in the health and social care field, culminating in the Health & Social Care Act 2012 which established the role of the HSCIC.

De-identification should focus on a computer science-based approach to de-identification, rather than manual approaches, or statistical methodologies.

Although the broad idea of the policy proposals is easy to understand, there is a need for evidence in the form of case studies of what the barriers are and what the potential benefits can be.

What is needed for the policy process?

  • Clarity about the need for legislation – why are current approaches inadequate?
  • Governance arrangements including the full range of processes;
  • Making clear what the public benefit is – the term means different things to different people

Discussion Groups

The workshop divided into five sub-groups to discuss their understanding of the proposals and any particular concerns. The content of these discussions is reported as follows:

Group A

Why is new legislation needed – is this legal barriers, or instead is it understanding, skills, knowledge etc of data sharing by the various protagonists?

Need more concrete examples of where there have been problems with data sharing particularly where the lack of legal clarity is an issue.

Need to document the progress of a project from initial conception through to publication of results, showing governance, roles (ADRN/ADS/Trusted Third Parties etc) and how de-identification takes place.

The position of HMRC raises special issues and these need to be considered separately.

Group B

Broadly understands the proposals, but has some caveats:

More detail about the proposals is needed. As currently articulated, will the public understand them? May be best to “chunk” the case for change thematically as follows:

  • safeguards;
  • benefits

The case in relation to commercial access is not black and white. For example, what is the position regarding privately funded institutions in the 3rd sector?

How to untangle the tensions between a desire to increase access, and the suspicion about why some bodies would want to seek access?

Group C

More detail is needed about the proposals. This includes:

Better understanding of the potential benefits – this should come from case studies.

Possible establish a working group to pull together the various case studies?

Action: All to submit potential case studies to Rufus Rottenberg.

Important to demonstrate:

  • The benefits to policy makers; and
  • The benefits to individual citizens

Need to  agree and articulate better what is meant by “public benefit”

Case studies:

  • Should cover “this is why this project mattered” – need to trawl more widely than just Government bodies.
  • Maybe pose hypothetical examples of what could happen with better data sharing
  • Mention past successes as well as what we want to do, or what we can’t do in current framework.
  • Highlight the inefficiency and waste of the current arrangements – time taken to develop data sharing proposals; cost of misallocated funds and poor policy decisions

Need to communicate with the public – ask the public what they think.

Action: ONS to identify cases that show the inefficiency of the current situation.

Group D

The timing of this process could be problematic given the background and recent events which may have influenced public opinion. Would specific gateways be more acceptable than a generic one?

Is there a political consensus on this, or will opinions be sharply divided?

Need to show the high level benefits – “what is the strap-line?”

What could be the unintended consequences of these proposals? Is the UK statistics Authority expanding its remit?

Group E

Need to have a deeper understanding of the objectives of the policy proposals.

Need to set out the privacy safeguards – avoid the risk of a “moral panic” over data sharing; the public needs better information  in advance – for example, the ONS “Beyond 2011” pattern of engagement/consultation  may be a good model to follow.

In response it was pointed out that there would be the opportunity for public engagement after the publication of the joint paper that these discussions are leading to

Need to emphasise the independence of the governing body, and provide clarity about:

  • Who can access data;
  • What the processes are;

How will proportionality issues, etc l be addressed?

Next Meeting of De-Identified data strand: 10.00-12.00, Thursday 15 May, at 70 Whitehall.

ONS | 23 Apr 2014 | Meeting note

Introduction

This is a meeting note of the first meeting of the ONS data sharing strand.

Attendees:

Rufus Rottenberg (Cabinet Office)
Simon Meats (Cabinet Office)
Peter Lawrence (Cabinet Office)
James Edmonds (ONS)
Tammy-Jo Johnson (ONS)
Olivia Varley-Winter (RSS)
Siobhan Carey (BIS)
John McIlwraith (DWP)
Emma Carr (Big Brother watch)
Mitch Riviere (HMRC)
Danny Bega (HMRC)
Sally Deffor (Open Knowledge Foundation)
Amanda Smith (Open Data Institute)
Oliver Butler (Law Commission)

Summary of discussion

  1. Rufus opened the meeting and welcomed attendees. Introductions were made.
  2. Members divided into three small groups to discuss ground rules. These were shared with the wider group.
  3. Whole group discussion of the ONS Briefing Proposal Note. These resulted in changes to the ONS Briefing Proposals document.
  4.  James Edmonds from ONS gave a presentation entitled: In Context: Access to Administrative Data for Official Statistics.

This concluded with a question and answer session:

Q. In compulsory surveys would questions not currently asked in census be asked?

A. This is possible. As policy requirements and the ONS’s survey strategy and programme develop new or different questions may be required.  ONS would have to make a case and gain parliamentary approval for which surveys and which questions were mandatory.

Q.  How would you balance the intrusion of compulsory surveys with the reduction of burden through administrative data assuage?

A. Questions will be answered wherever possible through administrative data. There will be occasions on which the data is not available. Departments can only gather data that they required for their administrative function; therefore ONS may use a compulsory to survey to gather this.

Q. Would a compulsory survey be an all citizen census or a sample survey?

A. We currently use the Census Act 1920 to carry out compulsory censuses, this will not change. We would anticipate using the new legislation to carry out compulsory sample surveys.

Q. How will you avoid headlines regarding targeting of particular groups for compulsory surveys or particular questions?

A. We have a very clear and transparent sampling framework. We will have to ensure that our processes continue to be transparent and that we can demonstrate this to the public, press and civil society groups.

Q. With the advances in technology, would it not be possible to produce all statistics through administrative data alone?

A. No, it is very difficult to link more than two pieces of administrative data reliably. We could not then link survey data. This would result in the requirement of a national population database which is not a popular or acceptable solution to many.

Q. The use of the powers will be limited to ONS, does this include contractors?

A. Generally only civil servants have access to the data. We do not currently contract out any data analysis and have no plans to do so. We did contract out some data processing during the census but the amount and type of work required for census is not comparable to our business as usual work.

Q. So will HMRC suddenly be sending all its data to ONS?

A. No. There is a strictly controlled process which provides transparency and assurance that we currently go through. This will not change. ONS will still have to go through many steps, including but not limited to:

  • identify a need,
  • discuss this with the data owner,
  • review the data sharing framework
  • make  a business case,
  • carry out a privacy impact assessment,
  • agree its purpose and use,
  • agree storage
  • provide ongoing assurance to the data owner

Q. Would business cases be published?

A. We can see no reason not to. We wish to be as transparent as possible so would be happy for this to be the case.

Plans for next meeting

The next meeting will be held on Friday the 9th May at the RSS (Rufus to send invites and details). The following suggestions were made for the agenda:

  • What would change if legislation was passed?
  • Identify policy issues that may be better or differently addressed through data sharing.
  • Evidence of need, why this is a pressing case, particularly for OGD’s (not ONS)

Actions

1 Success criteria, final bullet. Change to: Proposals are agreed by civil society and taken to the next stage. Rufus
2 Clarify tasks with Involve and ensure future agendas and papers are distributed in a timely manner and stakeholders are being engaged Rufus
3 Key assumptions, clarify final bullet point to say that briefings are not for public domain. Rufus
4 Prepare a document and brief talk on what would change if legislation was passed. Tammy-Jo
5 Review previous benefits document and begin to plan a session for 9/5 Rufus
6 Identify some scenarios of where data sharing would have been beneficial Siobhan