Independent Review into National Statistics

Dear Pat McFadden,

Independent Review into National Statistics

We welcome the independent review into the data collected and published by the Office for National Statistics (ONS). We are writing to you to ask that the terms of reference for this review take into consideration the full scope of the problems with national statistics, particularly in relation to data on sex and other protected characteristics.

The Women’s Budget Group (WBG) is the UK’s leading feminist economics think tank. Our analysis evidences the ways women and men (and different groups of women and men) are situated differently in the economy. Our work therefore relies on the collection and publication of robust data on the labour market, time use, caring responsibilities, social security, housing, etc., disaggregated by sex and other protected characteristics. Such data is also critical for policy makers.

Like others, we have become increasingly concerned about the accuracy and reliability of data collected and published by the ONS. We therefore warmly welcome the review you have commissioned jointly with the UK National Statistics Authority to be led by Sir Robert Devereux.

However, we are concerned to see proposals in the ONS business plan to scale back work in areas such as wellbeing and living standards to focus on core UK economic statistics.  While we accept that data on employment and growth are important, we do not think that other areas can be ignored. Women’s labour market participation is significantly impacted by their unpaid caring responsibilities, so data on time use and unpaid care is critical to any employment strategy. Furthermore, GDP is widely recognised as a limited measure of the overall health of the economy. Economic growth should never be seen as an end in itself, but rather a way to deliver improved public wellbeing. Data on health, wellbeing, unpaid work are critical for a rounded assessment.

There are a number of different issues that we believe the review should address:

1. Collection and measurement issues

Recent scrutiny of the Labour Force Survey (LFS) has highlighted major issues in labour market data collection, including declining response rates, volatility and gaps in capturing workforce trends. These challenges are not unique to the LFS. Similar issues affect other important datasets, such as the Family Resources Survey (FRS) and the Annual Survey of Hours and Earnings (ASHE).

Furthermore, recently the ONS changed its methodology in its Wealth and Assets Survey and introduced two measures that improved the reliability of the latest version but haven’t corrected it for earlier versions. The new methodology also includes a change on how the value of future pension income is converted into today’s terms, making analysis of the distribution of wealth across generations much less reliable.

We are also concerned about the ONS’s proposed changes to the Crime Survey England & Wales that would make it impossible to fully compare old modules with new modules, rendering long-term trend analysis on violence against women and girls difficult.

1. Improving data collection and engagement

Beyond the current issues set out above, the review should also address longstanding gaps in data. For example:

• Use of household-level data – income is not shared equally within households: household-based economic measurements obscure women’s individual financial situations and economic vulnerability, making women’s poverty and financial dependence invisible in national statistics. It is important that data is collected and published on an individual as well as household level.
• Measurement of unpaid work – Women do 50% more unpaid work than men and the gendered division of unpaid care is central to women’s economic inequality. However, official economic indicators often exclude this contribution. For example, women’s childcare alone is worth an estimated £140 billion annually, yet it remains invisible in GDP calculations.
• Quality of local-level data – Many key datasets lack the granularity needed to understand regional gender disparities in employment and economic security.

1. The risks of moving towards administrative data

One option the ONS is exploring is to replace or combine survey data with administrative data, which presents both opportunities and risks. While administrative data can improve real-time insights, it has significant limitations. Women, particularly unpaid carers and those in insecure work, are at risk of disappearing entirely from official statistics if we rely solely on administrative datasets, such as HMRC data to measure labour market activity, for example.

1. Problems with the census question on gender identity and the Sullivan Review

WBG welcomed the inclusion of a question on gender identity in the 2021 census. However, it is now clear that the wording of this question was confusing to many, leading to the data being unreliable. The Sullivan Review on data on sex and gender identity/reassignment has shown that these are often conflated into a single heading of ‘gender’, particularly in administrative data. This can lead to unreliable data for both characteristics. The ONS, and the census in particular, are often taken as the gold standard for question design, so have an important role in ensuring accurate data collection in this area.

Scope of the review

Any review of ONS data must be rooted in meaningful engagement with a wide range of stakeholders, particularly grassroots organisations and community groups who rely on accurate data to advocate for change. Those whose lives are being measured must have a voice in shaping how that measurement happens – not only as a matter of fairness and accountability, but because inclusive approaches lead to stronger, more representative statistics. This in turn supports the development of policy that genuinely reflects and meets the needs of all communities.

We would welcome an opportunity to discuss the scope of the review in greater detail. At a minimum, it must include an emphasis on improving data collection and disaggregation by sex and progress towards economic data collection and reporting at an individual rather than household level.

Yours Sincerely,

Dr Mary-Ann Stephenson, Director, Women’s Budget Group

CC Rt Hon Bridget Phillipson MP, Rt. Hon. Baroness Smith of Malvern, Sir Ian Diamond