House of Commons Public Administration Select Committee Official Statistics: 2011 Census
Written Evidence
This is a volume of submissions, relevant to the inquiry into Good Government, which have been reported to the House but not yet approved for publication in final form. Any public use of, or reference to, the contents should make clear that it is not yet an approved final record of the written evidence received by the Committee.
1 List of written evidence
Page
1 British Humanist Association (OSC 01), (OSC 02) 2, 10 2 Tyne & Wear Research and Information (OSC 03) 19 3 The Economic and Social Research Council (OSC 04) 21 4 Local Government Data Unit Wales (OSC 05) 25 5 British Society for Population Studies (OSC 06) 29 6 Royal Statistical Society (OSC 07) 33 7 Demographics User Group (OSC 08) 39 8 Market Research Society (OSC 09) 43 9 Equality and Human Rights Commission (OSC 10) 48 10 Dr Oliver Duke-Williams (OSC 11) 51 11 Electoral Commission (OSC 12) 60 12 Statistics User Forum (OSC 13) 63 13 Local Government Association (OSC 14) 65 14 Luton Borough Council (OSC 15) 72 15 Wandsworth Council (OSC 16) 76 16 Greater London Authority (OSC 17) 80 17 Westminster City Council (OSC 18) 83 18 Dame Karen Dunnell (OSC 19) 84
2 Memorandum from the British Humanist Association (OSC 01)
About the British Humanist Association
The British Humanist Association (BHA) is the national charity representing the interests of the large and growing population of ethically concerned, non-religious people living in the UK. It exists to support and represent people who seek to live good and responsible lives without religious or superstitious beliefs. It is committed to human rights and democracy, and has a long history of active engagement in work for an open and inclusive society.
The BHA’s policies are informed by its members, who include eminent authorities in many fields, and by other specialists and experts who share humanist values and concerns. The BHA is deeply committed to human rights and advocates an open and inclusive society in which individual freedom of belief and speech are supported by a policy of disinterested impartiality on the part of the Government and official bodies towards the many groups within society so long as they conform to the minimum conventions of the society.
Introduction
We understand that PASC is likely to be undertaking work on statistical issues related to the 2011 Census and we are pleased to make this early submission to the Committee on the Census question on religion.
A question on religion was included in the Census in England and Wales for the first time in 2001. It was added at a late stage and produced a grossly inaccurate measurement of the religiosity of the population: its underreporting of the non- religious population and its failure to reflect accurately either religious belief, religious practice or religious affiliation have produced a clear and damaging change in the direction of public policy on religion or belief.
The White Paper ‘Helping to shape tomorrow: The 2011 Census of Population and Housing in England and Wales’ (Cabinet Office, December 2008) proposes to use the same question1 as in 2001. This would reinforce and probably extend existing public policy in ways that are already producing discrimination based on religion or belief.
We have taken a full part in the public consultations about the 2011 Census and have had a number of meetings with the Office for National Statistics2 (ONS) to discuss alternatives for the Census question on religion. Initially they assured us that they understood and largely agreed with our concerns and would test a number of alternative questions.
1 With the minor change of ‘No religion’ in the list of suggested answers. 2 The Office for National Statistics (ONS) is the executive office of the UK Statistics Authority, a non- ministerial department which reports directly to Parliament.
3 In the event, the ONS tested only two alternative questions. One - as reported in the White paper proved predictably unsatisfactory. The other gave statistically significant and, we have reason to believe, more accurate figures, especially for Christians, Sikhs and non-religious people. This question they failed to mention to us until after the White Paper had been written and there is no mention of it in the White Paper.
They now propose to re-use the flawed 2001 question. Not only will this entrench the errors of 2001 but we consider the question potentially unlawful under the Human Rights Act 1998 (HRA) and the Equality Act 2006.
Summary of concerns
• We have had no real response to our legal questions as to how the ONS justifies using a question in the 2011 Census which will overestimate the number of religious people and underestimate the number of non-religious people and therefore be likely to lead to discrimination. Such discrimination, because it is not objectively justified, would be unlawful under both the Human Rights Act 1998 and the Equality Act 2006.
• We have had no answer to our concerns that the 2001 question measures cultural affiliation or identity, rather than religious affiliation or identity. (This is evidenced by the fact that the ONS accepted that a different question which measures religiosity more directly gives statistically significant changes: changes which are best explained by our view of the difference in what the questions measure.)
• We have had no answer from the ONS as to why it believes a measure of religious affiliation or identification (even if the 2001 question did measure religious affiliation or identity rather than cultural) will meet needs better than a measure of beliefs or practice.
• A question that purports to measure religion or belief (as it must do following the Equality Act 2006 and section 6 of the HRA 1998) is not compliant with that provision if by referring to religion in a way that may be perceived as cultural it fails to treat lack of religion equally with religion.
Proposed question on religion is unlawful under the Human Rights Act 1998 and under the Equality Act 2006
On 16th May 2008, soon after the ONS told us that they had reversed their previous intention to revise the question on religion, solicitors acting on behalf of the BHA wrote to Karen Dunnell, National Statistician, ONS, regarding our concern that we do not consider the decision lawful under the Equality Act 2006 and the Human Rights Act 1998. We claimed that the question is unlawful because it seeks to measure religious affiliation and because use of the data from the 2001 question has led to serious and significant discrimination against the non-religious.
4 The reply from the ONS, which was not written until seven months later, on 9th December, did not satisfactorily answer our concerns and we remain convinced that the proposed question remains unlawful. See both letters attached at appendices A and B.3
Data inaccurate and does not meet user needs
In preparation for the 2011 Census the ONS identified user for data relating to religion.4 These included resource allocation, meeting legislative requirements, policy targeting, working with what it called ‘faith communities’, identifying and tackling discrimination, meeting equality targets, and policy development.
This all suggested that the need was for high quality, accurate and reliable information on actual religious practice and/or ‘belonging’ to a religion as it might affect the needs of service users. We do not believe this information can be garnered from the data produced by the question ‘What is your religion?’.
The question ‘What is your religion?’ used in the 2001 Census and proposed for the 2011 Census gave a uniquely low figure for the non-religious compared with all other surveys. According to other, more accurate social surveys5 people who identify as not belonging to any religion make up nearly half the total population (sometimes more). Indeed, if you look at actual religious practice, current Church attendance stands at just 6.3% of the population6 - and is declining year on year. A tiny addition may be made for those of non-Christian religions but 90% of the population still are not regular attenders.
The under-representation of the non-religious, together with the widespread misuse of Census data on religion as if it measured actual belief, practice and/or ‘belonging’ to a religion and/or needs stemming from a religious position, is a serious issue. It is surely one reason why non-religious people are not included fully or at all in a variety of community initiatives; why they are disadvantaged by the disproportionate allocation of resources to those perceived as religious, and why they are not included fully in democratic processes and civic engagement, where these processes use religion as a category.
The 2001 Census question on religion actually measured cultural identification (and even then very crudely). To use such data in order, for example, to allocate resources or to extend to religious people and organisations privileged opportunities to influence and shape government policies for everyone in society on the basis that they represent a group whose size has been seriously exaggerated has potentially very serious consequences.
3 Not printed 4 Office for National Statistics Information paper. The 2011 Census: Assesment of initial user requirements on content for England and Wales – Ethnicity, identity, language and religion. March 2006 5 See, for example, Social Attitudes Survey 2007 among many other surveys 6 Christian Research, The 2005 English Church Census.
5
The Government and the ONS have recognised the inadequacy of the Census data. For example, in the Government’s response to the consultation on the Equality Bill, it said ‘reliable statistics are not avallable’ for ‘strands such as... religion or belief.7 Further, the ONS itself has said that there will be a need for guidance to clarify the data produced by the questions, because it is not a reliable indicator of religiosity.
The White Paper states ‘ONS acknowledges that the proposed question does not measure religious practice, and that for some user needs (particularly for service planning) a measure of practice may be useful’ (p52).
Despite this recognition of the inadequacy of the data, it is clear that ministers, local and other public authorities, Members of both Houses of Parliament, civil servants and others misuse the Census data on religion- interpreting them incorrectly and basing policies and actions on those misinterpretations. For example, a rationale behind the Government’s new ‘interfaith’ strategy and the accompanying £7.5 million in funding from the public purse (following on from a previous £12.5 million) is the Secretary of State for Communities and Local Government’s understanding, from the Census, that around 80% of the population of England and Wales have an active ‘faith’.8 We have been told by an official at the Department for Work and Pensions that they are ‘required’ to use census data to inform policy and practice, for example in relation to equality issues, and that this requirement almost certainly extends to other government departments.
Further, the notion that 72% of the population are ‘Christian’ has been used to justify the continuing presence of Bishops in the House of Lords, to justify the state- funding of faith schools (and their expansion), to justify and seek an increase in religious broadcasting and to exclude the voices of humanists in a number of contexts.
A different question
The BHA pressed for a different question in a series of meetings with the ONS - one which would provide reliable data on religious belief, practice or belonging or, at the very least, a genuine religious (as opposed to cultural) affiliation in the UK.
The ONS agreed to test a number of alternative questions. As mentioned in the White Paper, the question ‘What is your religion or belief?’ was tested but, unsurprisingly and predictably, this was poorly understood and did not provide any improved data.
Although it is not mentioned in the White Paper, the ONS then also tested the question ‘Do you regard yourself as belonging to a religion?’ and this produced
7 The Equality Bill – Government response to the Consultation, July 2008 8 Communities and Local Government Face to Face and Side by Side: A framework for partnership in our multi faith society, July 2008
6 statistically significant changes in the proportion of Christians, Sikhs and the non- religious. As would be expected, the proportion of Christians decreased, and the proportion of non-religious people increased.
The BHA was told by the ONS that they had decided not to propose this question for the 2011 Census because it produced a lower figure also for those following the Sikh religion. This was presumably because it did not capture non-religious Sikhs in England and Wales. A lower figure for the Sikh category was deemed unacceptable by the ONS.
Rather than change the existing question, which it agrees is flawed, the ONS has suggested that an adapted question be asked in social surveys as ‘the best way’9 to capture information relating to religious practice.
We believe that supplementary guidance on Census data on religion or using other social surveys to measure more accurately religion and belief in England and Wales is not at all a reasonable substitute for a changed question. The Census has by its prominence and by policy a pre-eminent position: bald Census figures will always carry far more weight, however flawed, than other, better surveys and riders and warnings about Census data will usually be overlooked or ignored.
It is clear that a question on religion, not least to be compliant with law, should not attempt to, or be used to, measure ethnicity. However, the reasoning given by the ONS suggests that is exactly the reason for rejecting the question ‘Do you consider yourself as belonging to a religion?’, in favour of retaining the 2001 question.
What the ONS is proposing is to use a question that they have agreed produces inaccurate figures for Christians, Sikhs and non-believers in order to capture an allegedly accurate figure for ethnic Sikhs. The obvious alternative is to use the ‘belonging’ question on religions and to include ‘Sikh’ as a category within the ethnicity section of the Census, as well as in the religion section.
Equality Impact Assessment
We consider that the ONS’s Equality Impact Assessment (EIA) on including the religion question in the 2011 Census to be woefully inadequate. The EIA contains an inaccurate definition from the Equality Act of ‘religion or belief’ and shows a misunderstanding of religion or belief and the various issues involved.
Recommendation 19 from the EIA states, ‘It is recommended that Census guidance notes explain the difference between a religion and a belief, with examples such as those given in the equality impact assessment.’ The fact that guidance needs to be produced simply to clarify what the difference is between a religion and a belief highlights that the question and the data gathered from it is not suitable for user needs. Second, and more importantly, given that even in the EIA there is a clear
9 Census 2011 White Paper, 2008
7 misunderstanding of the religion or belief equality strand in legal terms and otherwise, we are concerned about the quality of the guidance that may be written.
Inadequate response to Freedom of Information request
Having been made aware that the ONS had tested the question ‘Do you regard yourself as belonging to a religion?’ and that this had produced significantly different data from that produced by ‘What is your religion?’- data that was more consistent with more sophisticated studies of religion and belief in the UK - we submitted a Freedom of Information request to the ONS on 7 October 2008.
The FOI request specifically asked for ‘All papers dating from the current year about the choice of questions for the 2011 census on the subject of religion or belief, and in particular any cognitive and any field testing of questions carried out, including the wording of the questions tested, the size of the samples used and the aggregate answers produced, together with any papers assessing the results of the testing and making recommendations as to the question to be selected for use.’
The response - received on 3rd February 2009 after a quite unacceptable delay of almost four months - provided copies of some correspondence also requested in the FOI request, but nothing on the testing of the ‘belonging’ question or the results it produced. We have therefore to rely on what we are told at a meeting with the ONS and are not in a position to say exactly how closely the results mirrored the more accurate data from other studies: only that the data were more realistic than those from the proposed question.
Conclusion
It is clear to us that the question on religion proposed in the White Paper is not compliant with either the Equality Act 2006 or the Human Rights Act 1998.
We do not believe that the ONS has taken into account the legal implications of proposing to re-use the 2001 question on religion; the discriminatory impact of such a proposal, or the failure to meet the needs that potential users have clearly indicated, We are convinced that the question ‘What is your religion?’ should not be used in the 2011 Census. The question must be changed.10
It is clear that the ONS has failed to test enough alternative questions to establish which would capture the most accurate data on religion and belief, or to test alternative questions early enough in the process.
10 The ONS and others have suggested that asking the same question has the virtue in consistency. Other things being equal, consistency is desirable, but consistency in error is a mark of obstinacy, not of virtue, especially when the result is misdirection of public resources and policy.
8 The best solution even at this late stage would be to carry out this testing now. In light of the timescales required, we appreciate the difficulties this may present, and if it is genuinely impossible, an acceptable solution might be to use the question that produced the most meaningful data in testing and would come closest to meeting the identified user needs, namely ‘Do you regard yourself as belonging to a religion?’. To address the issue that this question identifies as Sikhs only those who consider themselves to belong to the Sikh religion, the ONS could explore other avenues, particularly the inclusion of ‘Sikh’ as a category in the ethnicity section, so that accurate data would be produced on both ethnicity and belief or belonging.
In the absence of a proper response to our FOl request, we do not know how accurate the data from the ‘belonging’ question would be. However, the ONS does know the results of its testing and thus how well the data correlates with that obtained from more sophisticated studies. The ONS must surely be required to divulge this information. Only then can a judgment be made as to whether ‘Do you regard yourself as belonging to a religion?’ is an acceptable question. All the indications are that it would be far better than the 2001 question. If not, then there is no alternative to testing additional questions.
March 2009
9 Supplementary memorandum from the British Humanist Association (OSC 02)
1. Introduction
In March, we made a submission to the Public Administration Select Committee (PASC) on the 2011 Census Question on Religion. Since that submission was made, the Office for National Statistics has published its ‘Information paper: Recommended questions for the 2009 Census Rehearsal and 2011 Census. Religion".11
In light of the ONS paper, we are further convinced that all the concerns we set out in our earlier submission to PASC are fully justified.
We hold that the proposed question on religion for the 2011 Census is wholly unsuitable, is arguably unlawful in light of the Equality Act 2006 and the Human Rights Act 1998, and risks being in breach of the forthcoming Equality Bill, which is set to become law well ahead of the next Census.
This short submission should be read in conjunction with our previous memorandum.
We would welcome the opportunity to provide oral evidence to the Committee, should it decide to investigate the matter of the Census 2011 further.
2. The uses to which the data will be put
Before examining the ONS’s attempt to justify its proposed question, we wish first to recall the uses to which the resulting data will be put by reference to the ONS paper ‘The 2011 Census: Assessment of initial user requirements on content for England and Wales’ (March 2006).12
Both the ODPM13 and the Home Office said that the data would ‘assist planning and allocation of resources’. The ODPM said the data was ‘crucial to our understanding of the changing nature and diversity of our communities’.
Local authorities said it would help them ‘target resource allocation [and] funding for ... education’ and would ‘support social and community cohesion initiatives such as community plans’.
‘Other data users’ mentioned ‘provision of resources to local education authorities for religious studies, introducing faith based welfare, monitoring discrimination and the provision of chaplains’.
11 Called ‘ONS paper’ from herein 12 http://www.onsgov. uk/about/consultations/closed-consultations/consultation-on-2011-census--- responses/ethnicity--identity--language—religion.pdf 13 Government departments have of course been reorganised since the consultation with users.
10
The DfES would use the data to evaluate ‘allegations of discrimination on the grounds of religion or belief [in] employment and vocational training and ... education’.
The then Commission for Racial Equality wanted ‘to promote and monitor equality amongst people of different faiths and beliefs’.
To summarise, the question is needed to inform resource allocation, to monitor compliance with duties not to discriminate, and to support community cohesion through a better understanding of society.
3. Summary of objection to ONS case
• The question proposed (as the ONS themselves now admit) is designed as a ‘leading question’ to capture the weakest possible religious affiliation, and is therefore quite unfitted to uses such as resource allocation and monitoring of discrimination. (Section 4 below)
• The justification provided by the ONS for their proposed question on religion is focused on meeting requirements relating to ethnicity under the Race Relations Act. (Section 5 below)
• The ONS have ignored or misunderstood current and impending equality legislation on religion or belief with the result that their proposed question on religion fails to meet legal requirements. (Section 6 below)
• The ONS have misunderstood the legal meaning of ‘religion or belief’ and specifically the legal standing of non-religious beliefs. (Section 7 below)
• The ONS have failed to test or take proper account of the results of testing alternative questions that would more accurately measure religion and non- religious beliefs. (Section 8 below)
4. The question is leading and collects misleading data
Given the uses to which the data will be put, one might have expected that the ONS would be concerned to ensure that something significant was being measured. However, not only do they reject (section 4 of their paper) the idea of measuring what people believe or how people behave, opting instead to measure the weaker concept of ‘affiliation’ - they then go on to decide to measure affiliation not by membership of a religious community or by ‘Identifying with particular church even if attendance is irregular’ but by the weakest possible concept of affiliation: as they say, the ‘question aims to include the weakest form of affiliation… (‘loose belonging including ethnic or family connections’)’ (p15). In their eyes, justification for ticking a religion includes ‘being christened or baptised, being married and choosing to getting married in
11 church. . .’ (p28). They say elsewhere (p48): ‘While the question is aimed at religious affiliation, it should not risk counting as Christian people who actually have no religious affiliation whatsoever’). Yet being baptised at the age of a few weeks apparently counts as a religious affliction.
The ONS do not apologise for the question (‘What is your religion?’) being a leading one. ‘Normally,’ (they say) ‘ONS aim to avoid asking leading questions such as ‘what is your religion?’ However,. . . a leading religion question is justified on the grounds that, by comparison to its alternatives, it is clear and encourages people with a loose affiliation to identify with a religion.’ (p26)
They claim that the question is ‘clear’ and ‘will help to minimise confusion’ (p15). Instead, it will create it. The public may gather that even if they are not religious they are expected to answer that they are (‘I have been christened, but I’m not religious.’ / ‘Well I’m going to put Christian down because I come from a Christian background’ (p28)) but users of the data will (as experience with the 2001 census has shown) misunderstand it.
Data users may not feel ‘confused’: they will think they understand - but in very many cases they will be wrong. Explanatory notes on the ONS website and monitory footnotes in reports will count for nothing. Claims that three-quarters of the population is Christian will continue to proliferate and not just that: they will continue to help shape policy and resource allocation at national and local level. Delegation of public service delivery to religious groups will accelerate, funds will continue to be lavished on religious organisations,14 and Church spokesmen (almost always men) will continue to have exaggerated influence. More schools will be handed over to religious sponsors, and religious education in non-faith schools will continue to be dominated by the ‘six world religions’ to the effective exclusion of non-religious beliefs despite the fact that two-thirds of teenagers15 and almost half of the population16 say they do not belong to a religion. Those who have no religion are therefore the victims of the ONS’s deliberate policy of maximising the positive responses to the question. Despite accumulating evidence they seem to think the non- religious do not care or do not matter.
All this is already happening as a result of the question rushed into the 2001 Census without adequate consultation. The ONS quote the virtue of consistency in favour of repeating the question: there is no virtue in consistency in error. Errors are best corrected as quickly as possible. With the census, that cannot be done within ten years - it would be appalling if in the name of consistency accurate and meaningful data was denied us for 20 or 30 years or longer.
14 In defiance of any non-discrimination, organisations representing the non-religious population were allocated less than 0.2% of the £13.3 million ‘Faith Community Capacity Building Fund’ 15 Young People in Britain: The Attitudes and Experiences of 12 to 19 year olds. DfES Research Report RR564, National Centre for Social Research 2004—ISBN 1 84478 291 3 16 British Social Attitudes Survey, National Centre for Social Research—in Table 13.18, Social Trends no 38, 2008
12
The ONS paper acknowledges that for some user needs additional information about practice may be useful because a measure of weak affiliation does not meet them. This is particularly true of resource allocation and service provision. They actually recommend that other surveys should have supplementary questions that capture belief and practice in order to meet such needs
They plead lack of space on Census form, privacy issues and difficulties with the Head of Household as the respondent as reasons why they do not wish to capture practice with the religion question (p26).
We do not believe that these reasons provide an adequate justification - not least in light of the considerable discrimination against non-religious people in the allocation of public resources and in other ways that is likely to result from the undercounting of non-religious people. This point is detailed fully in our main submission to PASC.
5. The ONS’s justification is focused on ethnicity, not religion
It is clear throughout their paper that the ONS see the religion question principally as an additional question on ethnicity and as needed to meet a legal requirement on racial monitoring that is not met by the proposed ethnicity question.
The decision to target such weak religious affiliation is based on their wish to capture the large proportions of non-religious people who may consider that they are Jewish or Sikh by ethnicity (as seen in law under the Race Relations Act) but not by religion, a point we discussed in our main submission. The ONS paper makes it explicit that the Race Relations Act is their primary for proposing such a ‘leading question’ in the 2011 Census. It states that ‘evidence suggests that the 2001 question [on religion] provides a reasonable proxy for Sikh and Jewish ethnic groups’ (p23).
One might have thought that the right place to capture data on ethnicity was the question on ethnicity. Yet the comparable report on the ethnicity question17 completely fails even to mention the issue. It does not include the word ‘Jew’/’Jewish’ once and has ‘Sikh’ only once, where it says that ‘a number of respondents to ONS consultations requested additional tick-boxes to be included in the question for ‘those who had18 a relevant tick-box in 2001 but were aggregated with other groups (for example Cornish, east African Asian, Kashmiri, Sikh, specific African groups)’ - with no further comment at all.
The ONS paper acknowledges that the position of the religion question in the questionnaire will also affect how people respond to it. Placing it within a suite of
17 http://www.ons.gov.uk/census/2011-cencus/2011-census-questionnaire-content/recommended- questions---ethnic-group.pdf
18 - or rather, did not have a tick box but when written in were aggregated in the way stated.
13 questions after ethnicity and nationality means that respondents will associate those identities:
‘I’m White British therefore I must be Christian’ (Voas and Bruce 2004:27).’ Since the religious affiliation question is intended to measure just that - individuals with a cultural affiliation with a religion, ONS did not see this association as a problem (p54).
This makes absolutely clear that the ONS are not interested in accurate data on religion. They are interested in additional data on ethnicity.
6. The ONS have ignored or misunderstood equality legislation on religion or belief
Importantly, while the ONS might have been able to justify having a religion question that was actually a proxy for ethnicity in 2001, they cannot for 2011, when public authorities have duties not to discriminate on grounds of religion or belief and there will almost certainly be a public duty to promote equality not only on race but also on religion or belief- duties which their religion question will not meet.
As we stated in our main submission, a question that purports to measure religion or belief is not compliant with the Equality Act 2006 and the Human Rights Act 1998 if by referring to religion in a way that may be perceived as cultural it fails to treat lack of religion equally with religion.
It is clear from their paper that the ONS have simply not addressed this issue at all. They have paid no regard to section 52 of the Equality Act 2006 or to section 6 of the Human Rights Act 1998. They have also failed to anticipate the forthcoming Equality Bill, which will replace all existing equalities legislation and is likely to have a public sector duty to promote equality as regards religion or belief and to be in effect before the next Census takes place. We find this astounding - and it is not out of ignorance, for we have ourselves drawn attention to the legislation. Instead, the ONS seem simply to have decided to ignore the law.
7. The ONS have misunderstood the legal meaning of ‘religion or belief
Section 7.3 of the ONS paper seems to misunderstand legislation and legal terminology covering the religion or belief equality strand. Instead of going back to the law itself, they appear to have relied on secondary sources, and in all three of their fundamental propositions (p34) their reliance is misplaced:
‘Religion or belief was defined in the Employment Equality (Religion or Belief) Regulations 2003 as ‘any religion, religious belief, or similar philosophical belief’ for example atheism and humanism but excluded ‘any philosophical or political belief unless that belief is similar to a religious belief’. (Commission for Racial Equality 2007)’
14
‘To be protected under the Equality Act 2006, a religion or belief must be recognised as being cogent, serious, cohesive and compatible with human dignity. The concept includes religions that are widely recognised in Britain (Equality and Human Rights Commission 2008).’
‘According to the Employment Equality (Religion or Belief) Regulations 2003, a religion is characterised by collective worship, or a clear belief system, or a profound belief that affects a way of life or a world view (Commission for Racial Equality 2007).’ The Employment Equality (Religion or Belief) Regulations 2003 have been amended, and the definitions have been changed. Although the ONS refer elsewhere to the 2006 Equality Act, they seem unaware that it changed the definition of a ‘belief’ in the Employment Regulations so that it no longer has to be ‘similar’ to a religion but is ‘any religious or philosophical belief’ and ‘a reference to belief includes a reference to lack of belief’.
It follows that the law’s protection extends to atheism, agnosticism or complete lack of belief- so the case law on ‘being cogent, serious, cohesive and compatible with human dignity’ has been misapplied.
Nor do the 2003 Regulations say anything about a religion being characterised ‘by collective worship, or a clear belief system, or a profound belief that affects a way of life or a world view’.
That the ONS can get the law so wrong is astounding. Can they be trusted to produce guidance on use of the Census data that will offset the severe repercussions for non- religious people of an uninformed reading if they themselves do not understand what is meant by religion or belief? The Equality Impact Assessment to which the ONS paper refers is certainly insufficient - we discussed that in our main submission.
In discussion of the Equality Act 2006, the ONS’s interpretation that it ‘is unlawful to discriminate against a person because of their affiliation to a religion or belief even if they are not practising or believers’ is right so far as it goes. Yet their conclusion does not follow, ‘A religious affiliation question will therefore meet user needs under this new legislation’.
Further, in 7.3.2 and 7.12 there is a discussion about recording non-religious beliefs - including the statement that ‘people with a religious affiliation or beliefs may, for example, be humanists, atheists or agnostics’. This amazing statement would normally stop the reader short but by this stage the depth of the ONS’s misunderstanding of non-religious beliefs makes it merely disappointing.
8. Testing of alternative questions to capture non-religious beliefs was not sufficient
15 The ONS paper reports the testing of two alternative questions, both of which they rejected. We are especially concerned with their reasons for rejecting the question, ‘Do you regard yourself as belonging to a religion?’ as mentioned in our main submission to PASC. In light of new information from the ONS paper and from a Freedom of Information request, we make these supplementary points about both questions.
Do you regard yourself as belonging to a religion?
Annex A in the ONS paper provides an analysis of the results of testing the question ‘Do you regard yourself as belonging to a religion?’ and shows that the difference in response rates for ‘Christian’, ‘Sikh’ and ‘No religion’ are statistically significant. Yet the ONS did not cognitively test this question, justifying the omission by pointing to cognitive testing of a similar (but different) question over 10 years ago in 1997.
The question was rejected specifically because it did not capture the ethnic Sikh population, with a potential ‘undercount’ (more likely, a similarly more accurate count) of other minority religions. The failure to test this question properly and its subsequent rejection is clearly counter to good research methods, to good practice in demography and to capturing data adapted to recognised user needs. It makes it absolutely clear that the ‘religion question’ is actually a supplementary ethnicity question, and not one to measure religion or belief.
What is your religion or belief?
In papers released by the ONS on the Wave 5 testing, following a Freedom of Information request, they state that the question ‘what is your religion or belief’ worked well and that the respondents had a good understanding of what it was asking, and recommended that it is put forward in its current format for the 2009 Census Rehearsal. This is confusing considering that the ONS Paper states that the term belief was not understood and as such the ONS rejected the question.
What is more remarkable however is the Wave 6 ‘Testing Report’, which describes, without giving clear reasons, how the ONS changed this decision to revert to the ‘what is your religion question’ and got rid of the response examples next to the ‘No religion’ tick box: (including Humanist, Atheist Agnostic). The two questions produced statistically significant differences for ‘Christian’ and ‘No religion’, with higher numbers of ‘No religion’. In that Report it states that ‘Those who describe themselves as Atheist or Agnostic had more trouble finding a suitable box to select in this wave compared with Wave 5’.
In neither the Wave 6 ‘Testing Report’ nor in the ONS Paper is there discussion of what exactly caused the difficulty in finding an appropriate place for non-religious people to record their beliefs.
16 Conclusion
Finally we wish to underline the significance of the wording of the question. What is purportedly being measured is religion. The resulting data will inform the self- perception of the population, the shape of public debate, the creation of government policy and the allocation of public resources. These are not trivial matters.
The answers to questions about religion are notoriously sensitive to the wording of the question and the way it is asked. In such circumstances, a question to be asked in the Census needs to be framed with the greatest of care. Given the difficulties, the ONS should err on the side of caution, in the sense of avoiding any question that will predictably yield extreme answers.
Yet the ONS has done exactly the opposite. The 2001 Census produced a Christian cohort far larger than any other survey or poll in recent times. It did so - and the ONS propose to do the same in 2011 – by:
• Asking a leading question • Asking a single question, rather than first asking whether respondents have a religion or not • Framing the question to capture the loosest possible religious affiliation • Placing the question in a group with questions of nationality and ethnicity • Administering the question through heads of household, many of whom may answer for their family members.
It is difficult to think of any additional ways the apparent size of the religious - especially the Christian - population could be boosted. The ONS are operating under constraints, but they seem blithely unaware of the implications of their recommendations. The impact on the non-religious population is extreme. Contrast the results of the Census in 2001 with those of the question the ONS rejected and with the comparable questions asked in the British Social Attitudes survey in 2006:
Census 20011 Test question—June British Social Attitudes 2008 survey—2006 ‘What is your ‘Do you regard ‘Do you regard religion?’ yourself as belonging yourself as belonging (England) to a religion?’ to any particular religion?’ with follow- up if answered ‘yes’ Christian 71.7 64.9 47.5 No religion 14.6 28.9 45.8
17 Are the non-religious 1 in 7 of the population - or 1 in 2? On what basis should Government policy be formed?
Parliament should require the ONS to produce a new question that is neither directly nor indirectly discriminatory against those who have no religion. If for any reason that proves impossible, the religion question should be removed from the Census altogether. It would be less damaging to have no question at all than to have a question that misinforms and misleads policy-makers and others who require information on religion and belief.
April 2009
18 Memorandum from Tyne & Wear Research and Information (OSC 03)
Tyne & Wear Research and Information would like to thank the Public Administration Select Committee (PASC) for the opportunity to provide comments on ‘Progress Towards 2011 Census’.
This submission is being made by Tyne & Wear Research and Information (TWRI) on behalf of the five Tyne & Wear Local Authority Districts (Gateshead, Newcastle, North Tyneside, South Tyneside, and Sunderland) without prejudice to any submissions made by the Districts on an individual basis.
1. The Tyne & Wear Local Authority Districts (TW LADs) would like to highlight the fact that Census data is of vital importance for the planning and delivery of services to local government. However, although TW LADs recognise the importance of Census data as being the best available, we would like to see this complemented by the use of official statistics, such as, for example, benefits data. An important element to this end would be to increase the availability and compatibility of statistics held by the various arms of government to complement data in the Census.
2. In the questionnaire format to be used in the upcoming Census rehearsal, the allocation of students to their respective places of study and development of linkages between these places and their original places of residence will depend entirely on a consistently successful return of responses from students at their term-time addresses. As this has been an untypical outcome in past Censuses, how does ONS intend to ensure a full and geographically reliable student enumeration in 2011? We look forward to ONS’ response on this question.
3. TW LADs have concerns regarding a potential undercount in urban areas. The TW LADs are aware that ONS have taken some measures to help address this, such as address matching, community reps, publicity drives etc, but feel that these measures may not be sufficient. We would be grateful to know of any further measures which ONS are planning to undertake to help minimise this.
4. TW LADs have concerns regarding ONS’ address matching exercise. This relates to LAs not being able to amend their own address records (e.g. gazetteers) where errors are found, as a result of ONS’ Postcode Address File (PAF) licence issues. As we understand it, LAs must carry out their own survey if they want to amend erroneous property records because the terms of the ONS licence do not allow the results to be used by LAs. There would be potential cost and efficiency savings if this could be rectified.
19 5. We would like to raise three questions in relation to the use of on-line Census forms:
a) How will ONS deal with duplicate responses? It is possible that a member of a household may send a paper return and their partner an electronic one. Which would be regarded by ONS as the valid response and how would any discrepancies between the two be reconciled?
b) Will scanning back and forward through the questionnaire (both in advance of and during the process of completing it) be permitted? This is frequently helpful in interpreting how a question should be answered and in providing answers at later points in the form that are consistent with those given earlier. Both of these will improve the ultimate standard of accuracy in the return
c) We feel that a low proportion of respondents will attempt to complete the form on-line. [Experience from running other on-line surveys indicates that relatively low numbers of people will adopt this form of response.]
The TW LADs would again like to thank the Public Administration Select Committee for the opportunity to contribute to this consultation exercise and look forward to hearing the outcome. We would also welcome the opportunity to be involved in any further consultations on related matters.
June 2009
20 Memorandum from The Economic and Social Research Council (OSC 04)
Summary
1. The Economic and Social Research Council (ESRC) operates a Census Programme to support UK academic access to, and use of, census data. The programme provides online data services and expert user support to researchers, teachers and students in the UK academic community and is thus centrally concerned with the specification and delivery of the 2011 UK censuses. The key aspects of our submission are:
• General satisfaction with progress in 2011 census planning;
• Satisfaction with the census organizations’ engagement with the academic community regarding 2011 requirements, although some concern as to how users’ views are incorporated into decision-making;
• Approval of the broad approach being adopted by the census agencies towards planning and production of census outputs, although users have not yet seen detailed proposals;
• Anxiety concerning the details and funding of outputs production which will need to take place after 2011 and for which detailed plans are not yet in place;
• Ongoing concern about aspects of the differences between the census organizations in the different parts of the UK;
• Ongoing concern regarding the implications of the lack of a definitive address register for the census;
• A warning that it is unrealistic to entirely separate consideration of the 2011 census from subsequent developments in population statistics. 2011 presents a unique opportunity to evaluate the effectiveness of administrative data sources which may play an important role beyond 2011 but there are aspects of this work which must be addressed as an integral part of the census processing.
Detailed submission
2. ESRC funds research and training in social and economic issues. It is an independent organisation, established by Royal Charter, but receives most of its funding through the Department for Business, Innovation and Skills. As part of its activities, ESRC funds a Census Programme at a cost of £8.4m during the period 2006-11, delivered through a network of user support services and research projects based across ten UK universities. The programme is the principal channel by which UK academic users obtain access to census data. ESRC was a 2001 Census Access Partner with ONS and commissioned the 2001 census Samples of Anonymised
21 Records. The programme is thus centrally concerned with the specification and delivery of census data.
3. We welcome the broad outline of the planning for the 2011 censuses, which is clearly focused on addressing recognised shortcomings in the 2001 census design and implementation and which also acknowledges the additional challenges that will face the census in 2011. In particular, concentration of effort on producing a high quality address register, the adoption of a targeted enumeration strategy, more sophisticated form tracking, introduction of an internet channel for enumeration, an extensive coverage survey and estimation system are all important and welcome developments.
4. The census organizations have engaged in a wide range of consultation activities concerning the planning for the 2011 census and members of the programme have had appropriate opportunities to respond and to represent the needs of academic users. We have some concerns regarding how user views are taken into account: for example the process of question selection saw the introduction of a relatively untested question on intention to remain in the UK largely unrelated to previous user consultation and at the same time the loss of a question on income which had been strongly supported by the research community. Thus the final topics do not reflect the balance of priorities as expressed by users in response to earlier consultations. Nevertheless the census organizations have maintained an ongoing range of meetings for the discussion of census requirements with key user communities in which academic users are represented. We anticipate that these channels will resolve many of the lesser questions and concerns regarding 2011 in due course.
5. We approve the broad approach being adopted by the census agencies towards planning and production of census outputs, although we have not yet seen details of what outputs are proposed or the access and costing models to be applied. This is an area both of great potential and great risk, but it is not possible to form a mature judgement of the 2011 plans yet. The current PASC call for views comes shortly before ONS begin a major consultation exercise on census outputs and it is therefore not possible to comment in detail on 2011 plans at this stage. We welcome the initial intention to look towards new web-based technologies as the underpinning architecture for census data dissemination as these will be best placed to service the great majority of users and access routes. It would be extremely unfortunate if the design of 2011 census outputs were to be narrowly confined to the production of tables and output products defined in the same terms as in 2001. The creation of a new ONS census outputs working group with broad cross-sectoral representation is a welcome development. It is imperative that once the outputs strategy is approved, ONS avoid late changes to the specifications, for example those occurring in 2001 due to late changes in statistical disclosure control policy. Such changes delay production and reduce the analytical value of census outputs while at the same time increasing costs to users through knock-on delays to many other activities.
22 6. We note with anxiety that the funding of census outputs production which will need to take place after 2011 is not yet assured. We understand that the ONS still needs to secure around £30m of funding for census processing work to take place after 2011 and that much of this expenditure is concerned with the creation of outputs. It is of great concern that this relatively small proportion of the entire census expenditure is likely to be most under pressure when it contributes so greatly to the utility, quality and timeliness of the census results delivered to users. This situation increases the risk of damage to census outputs through late changes, expressed in our concerns at paragraph 5 above. From the perspective of the academic research community, the planning for census outputs needs to encompass the entire range of outputs, from the widely distributed aggregate data tables and geographical boundaries to microdata samples and linked longitudinal files which can only be accessed by approved researchers in secure settings. The latter, more specialised outputs provide a disproportionately rich research resource for understanding UK society.
7. We have ongoing concern about aspects of the differences between the census organizations in the different parts of the UK, although the efforts of the Registrars General to work together, for example on matters of statistical disclosure control, are greatly welcomed. Divergence in question topics, geographical bases and population bases will already make UK-wide analysis difficult. In particular, the absence from the Scottish census of a question on intention to remain in the UK seems likely to prevent the calculation of UK-wide statistics on a consistent population basis, as this question will be used to remove short-term migrants from the resident count. This is of is of great significance to the research community, where there is often an explicit remit to understand UK-wide patterns, especially with regard to research and policy interest in short term migration and visitors counts. It is essential that in 2011 it is possible to obtain UK census results on a consistent basis from a single source, which allows the user to clearly identify comparable outputs and to be alerted to definitional and procedural differences which may impact on subsequent analysis of the data.
8. The use of mail-out and mail-back for the great majority of census enumeration will place even greater reliance on the quality of the census address list than in 2001. The ONS are undertaking an ambitious programme of work on the reconciliation of the two principal address products from Royal Mail/Ordnance Survey and the National Land and Property Gazetteer. Two aspects of this work are of concern: firstly that there is as yet little evidence of the sufficiency of this approach for census address listing purposes and secondly that so much effort and expenditure should be expended on reconciling two national data sources into a near-definitive national resource which will not be maintained for ongoing research and service delivery purposes.
9. It is unrealistic to entirely separate consideration of the 2011 census from subsequent developments in population statistics. The ONS already propose to make substantial use of administrative data sources in the quality assurance work necessary
23 for 2011 census and this is entirely appropriate. It will be necessary to thoroughly understand the relationships between these sources and the census population estimates by the time that 2011 counts are produced. If properly carried out, this process will present a unique opportunity to evaluate the effectiveness of administrative data sources which may play an important role beyond 2011 and it is critical that this work should not be viewed in a census "silo" but rather that the substantial census effort be directed so as to maximise the lessons learned about future population data sources.
June 2009
24 Memorandum from Local Government Data Unit Wales (OSC 05)
Summary of key points Local government has a duty to ensure the census provides reliable and complete information. We need that to deliver and plan resources and services for those affected in our sphere of influence. • Local government is aware of the national financial situation and strives to support the ONS. However, whilst recognising the importance of the census, resources are scarce and priorities in local government vary greatly. • It is essential that the investment in the census address list is not wasted and that the register remains available to the nation after the census. • The primary aim of the census must be to gain a reliable population count and distribution. This should not be put at risk by any of the questions asked. • Much of the contact between local government and the public relates to their perception of a community. The planning is towards statistical geographies with no firm commitments to the administrative areas with which people can identify. • We wish to ensure the greatest return on investment for “UK plc” from the census, including range and utility of outputs.
Introduction 1 The Local Government Data Unit – Wales welcomes this opportunity to provide information to the Select Committee. We have been working on behalf of the Welsh Local Government Association, local authorities in Wales with the ONS and the Welsh Assembly Government in the preparation of the 2011 census. 2 We applaud the many improvements from the last census in 2001 and will make our best efforts to support the 2011 census. There are always ways to improve and this paper focuses on those, but does not forget the good work already in place. 3 Welsh local government is concerned about the outcome of the census for the following reasons; • The distribution of basic funding both to and within authority areas, • Planning and the delivery of service, • Evidence for policy and strategy development, • A benchmark and base from which to measure performance, and • For public information and educational purposes. 4 If this is the last conventional census, there is a critical need for an accurate count and distribution of population from which to go forward. 5 This response will be divided into four basic parts; planning, collecting, delivering and risks, to address the questions of the Committee;
25 • Whether the project is proceeding in a timely and cost-efficient way, and • Whether it will produce sufficiently reliable, relevant and useful data.
Planning the census 6 Local government is all too well aware of the financial state of the nation and is trying to contribute to the recovery. There seems to be an expectation from the ONS of uniform resources for support from all local authorities. This may not be true, as in Wales they vary in population from 55,600 population to 320,000. Thus having vastly different capabilities and priorities for allocating scarce resources and expertise. Whilst local government acknowledges the importance of the census to their work, it must be recognised that even working together, resources are scarce and top priorities differ. 7 It is important that the ONS circulate clear expectations and a time line for delivery, so that local government can plan how best it can support the work programme. 8 The primary aim of this census must be a reliable population count and distribution. This is because the census and derived estimates of population, in the years when there is no census, are fundamental to the delivery of finance to local government. Also for local government on which to base service delivery and policy development. This requires local authority and sub-local authority information, not available from sample surveys (or less than 100% censuses). 9 Where this scarce resource is employed, it is not always certain that ONS listen to the expert advice when supplied. There is a perception that “liaison” groups only receive information from ONS and are not perceived as partners by ONS. Local government recognises the expertise of ONS staff, but the ONS should recognise the depth of experience and knowledge those in local government have to offer the project. 10 Resource and intellectual property right issues affect the capability of organisations to assist the ONS to develop the census address list, central to good enumeration. This new list should help to minimise the problems of under enumeration encountered in 2001. A great deal of effort and cost has been required to produce a “national” list. It would be tragic if it were not available as a bilingual (English and Welsh) list in the public interest after the census. 11 Local authorities do well with limited staff to develop and maintain number and address lists locally, which feed the National Land and Property Gazetteer (NLPG). The NLPG is a compilation of the local lists of legal addresses created by local government (under the Town Improvement Clauses Act 1847 and subsequent legislation). The volume of addresses from the census address list that will typically need to be checked, to validate that list, is not yet clear to local authorities. To help plan their support, the earliest publication of the report on the testing that was done and some indication of resource requirement, is needed.
26 12 There are many and varied pressures for questions to be asked in a census. It is critical that no question prejudices the response rate. Whilst particular issues may be particularly important in this volatile time, it will be important to review response in relation to questions after the rehearsal. 13 Although collection is based on households, the distribution of information is based on “output geographies”. Local government is one of a family of administrative geographies based on people’s perception of their “community”. For the 2001 census, new “statistical geographies” were developed to aid the comparison of information. Whilst the statistical geographies have their merit, a great deal of the conversation with clients and public is based on “community” areas. These “community” boundaries are those identified by the Boundary Commission for Wales when inquiring into people’s perception of their “community”. It is important that statistics are available for both communication with the people and for statistical purity. Without this there will be a reduction in utility of the outputs, as was the case in 2001 (community council basic statistics were promised but not produced).
Collecting the data 14 Whilst welcoming the planning for multi-media responses to the census, it should be noted that despite efforts of the Welsh Assembly Government, much of Wales does not have access to broadband. If the planning is for 25% response other than by paper, it will be necessary to be sure a skewed geographical distribution of response has been anticipated. In a recent report (DCLG Rural Reference Bulletin – Digital Inclusion, May 2009) it was noted that “only 1.5% of homes in villages and hamlets can access cable based broadband services” compared to 60% in urban areas. Although not so extensive as the lack of broadband, there are areas in Wales that are still unable to pick up a mobile phone signal, which would restrict that avenue for response also. 15 The effects of rurality were recognised during the early testing phases for address checking. Rurality will compound the difficulties in reaching some groups of people who may not be engaged with the census process.
Delivering the benefits 16 It is important that we plan to deliver the census outputs free at the point of use, as in previous years. It is encouraging that ONS are talking about web delivery as one option. To best use the data, it is important that map information be published to define the boundaries of all types of geography for which statistics are prepared and these are without cost. 17 To maximise the utility of the statistics produced, it is essential that the census continues to provide comprehensive small area statistics. It is the only current source where a wide variety of topics are “joined up”. This is essential for joined up local services to local communities. In the 2001 census community statistics were promised but never published. These areas could not be synthesised due to
27 disclosure control and incompatible small statistical geographies. Local government requires sub-authority statistical and administrative geographies to analyse, engage with and deliver to the people. 18 There is also talk of making medium sensitivity statistical data available to registered researchers. It is recognised that more sensitive statistical data would need to be handled in controlled conditions in ONS locations. However, it would increase the value of medium sensitive, such as unrounded origin destination sets, if researchers did not have to travel for hours just to reach ONS offices in which to process the data.
Risks 19 Local authorities have concerns, that if scarce resources limit their input to the census planning and preparation, that there may be a “blame culture” for any sub-optimal outcomes beyond their control. Which is why the issue of resource is being raised at an early stage in development. 20 Certain aspects of the census have enormous potential for payback, but need to be carefully controlled or considered. These areas of concern are; • the investment in the address register must provide continued benefits in the public interest, • effects of disclosure control on the value of outputs, or imposing access conditions, that limit the usability of data, • comparability across UK, • ability to identify changes in population characteristics from previous censuses, • the ability of the public to identify their “community” using published geographies, and • To ensure the investment by “UK plc” is maximised, not just for a single census, this requires outputs to be adequate for user needs and fit for purpose (especially as proposals for future statistical information may come from record linkage, needing a good benchmark to begin with).
June 2009
28 Memorandum from British Society for Population Studies (BSPS) (OSC 06)
1. The British Society for Population Studies is the professional association of demographers and associated researchers in Britain. Some individual members have been centrally involved in census preparations and design of past censuses. Many members rely on high quality outputs from the census in order to pursue their research, planning and policy responsibilities.
2. This commentary on preparations for the 2011 Census is sent on behalf of BSPS Council. It is written with the benefit of papers written by the ONS and their discussion on June 1st 2009 at the Royal Statistical Society, organised by the ESRC Census Programme.
3. This commentary focuses on the preparations to produce the best possible estimates of population in mid-2011, with age and sex composition, of each local authority area in the UK. These estimates determine the resources provided for local services, and are the platform for all population studies and projections for the following decade.
4. Good population estimates for mid-2011 will draw on as full an enumeration as possible and a reliable estimate of those missed.
Aims and overall strategy
5. The twin aims to minimise non-response and to focus census fieldwork on areas of high non-response in order to reduce the variation in quality between areas, are fully supported. These aims are technically fundamental to good quality. They also acknowledge that a good census in most places is no consolation to any area where fieldwork or estimation procedures might fail. The concerns expressed below are intended to increase the likelihood that these aims are met.
6. Some might argue that good enumeration is all that is required, and that no estimation of those missed should be attempted, as it will always be uncertain and contested. We do not agree with this argument. In 2001, 3.5m of the estimated population were not included on census returns as residents, and were concentrated in cities, among young adults particularly men, and particular groups of the population. Without the inclusion of records to represent those missed, the census itself, and resource distribution based upon it, would have been significantly biased. Our concerns are expressed below within the context of strong support for the framework in which the Census offices are attempting to provide good population estimates.
Fieldwork
29 7. The use of post-out and post-back of census forms relies very heavily on the quality of the address list used in the Census. All efforts should be made to ensure it is up to date, with full open and public involvement of the local authorities who not only have local information but who will be rightly aggrieved if the census suffers from under-use of that information. We are satisfied with the strategy, but encourage Parliament and government to stress the importance of local authority engagement with the checking and improvement of the census address list in the timescales negotiated by the census offices with the Local Government Association.
8. The focus of fieldwork on follow-up, to increase response generally, but in particular in the areas of greatest initial non-response, requires great flexibility and initiative on the part of local Census managers. There is a tension between the efficient provision of services and management information from the central management team, and the need to react quickly and efficiently in response to local circumstances. One of the greatest criticisms of the fieldwork of the 2001 Census was precisely the surfeit of red tape and the lack of resources and freedom for local managers to take charge of operations. This is an area in which the ONS would do well to give high priority in rehearsal and in preparations leading up to 2011, since the 2011 Census is even more dependent on the initiative of local managers to ‘mop up’ as many non- respondents as possible in a relatively very short time. If in any locality a field force is frustrated by central control or by remote sub-contracted support services for everything from enumerator recruitment to stationery supply, it will not be efficient and could become demoralised.
9. There are as yet no plans to ask the field workers to return to households where returned forms are incomplete. In 2001, the only questions to receive valid answers in as many as 99% of returned forms were age, sex and marital status and it is no accident that these were the three questions checked locally by the field workers. Central postback of forms makes this more difficult, but we are concerned that a poor quality of age and sex information at collection will have significant impact on all the subsequent processes of estimation of missing people.
Estimation of non-response
10. We are generally confident in the approach to estimation, involving a large Census Coverage Survey shortly after the census, estimation of those missed by the Census based on matching of this survey to the census, and validation of the Census-based population estimates against other sources of information. This is the same approach taken in 2001, and in different forms the same approach as in previous censuses too.
30 11. In 2001, this approach estimated in a plausible way 2.9m non-respondents, allocating records to represent them in the Census database, and including them in population estimates. For 2011, a number of improvements have been planned, including census questions which will help to distinguish residents from temporary visitors, for example, and a greater focus of the field workers on converting non-respondents into respondents.
12. However, the approach has an Achilles heel, in that some people through personal circumstances or through unwillingness to co-operate will be less likely to be counted in either the census or the coverage survey. Fieldwork failures can also disturb the accuracy of estimation. This ‘lack of independence’, or bias, in the census population estimates requires a third source (or more) of information to allow an estimate of these extra people missed. Though their number is relatively small – estimated for 2001 as 0.5m – they are expected to be clustered in particular areas and sub-groups, to the extent that the main purposes of the census and population estimates would be poorly served in some areas unless further enhancements to the census can be made.
13. A crisis in confidence in the Census was triggered during 2002 when not a single adjustment was made to the census estimates despite one fifth of the 14,000 comparisons made with administrative data showing large discrepancies. The comparisons made were not released into the public domain until three months after decisions had been made that affected public distribution of resources. Some amendments were made by the ONS to the population estimates at regional level based on comparison of the Census to the Labour Force Survey sampling frame, but these amendments were unplanned and their documentation remains in draft form to this day. Discussion centred on the number of unmonitored emigrants during the 1990s and on two cases of fieldwork failure in Manchester and Westminster. The post-census validation contained too much in the nature of statistical fire- fighting.
14. It is essential that the census offices avoid another crisis of confidence in the census and the population estimates in 2011. At present it is assembling a series of administrative data sources and ‘demographic analyses’ with which to validate the census estimates. However, this is no more than was achieved in 2001.
15. The missing ingredients are:
a. A set of criteria to determine when the census-based estimate should normally be rejected for a particular area. b. A clear and routine process for adjusting the census estimate if it is initially rejected.
31
16. Judgement should also be used before rejecting the census estimate, but clear criteria should be prepared through statistical indicators of major discrepancies. These may come through comparison with administrative data or through demographic analysis or a combination of the two.
17. A routine, pre-planned process for adjusting the census estimate is essential for confidence in the census results. It is likely that most sources of administrative counts which can be used to highlight probable failures in the census, are not themselves sufficiently good counts of all residents to use instead of the census. It may be that direct linking of census, coverage survey, and individual administrative records provide a means of estimating the proportion missed by the census estimate, but this has yet to be determined. The most stable and predictable demographic analyses, such as local sex ratios relative to the national rate, must be investigated now sufficiently to decide how they would be used in practice in amending the census.
18. After investigation, it may be felt that no amendment process can be so routine and inexpensive as to be applied everywhere, but that some record-linking approach as in Manchester and Westminster after the 2001 Census would settle any doubts about the census estimates. Again, such a strategy should be discussed and agreed well before the census is undertaken.
19. In summary the British Society for Population Studies stresses the importance of the 2011 Census to government and research, supports the aims of the UK census offices and their strategy to achieve them, but believes that several key holes in the strategy must be filled in the Census Rehearsal and during the coming two years. We trust that the Parliamentary Committee will support the census offices in addressing these concerns.
References: • Local Government Association (2003) The 2001 One Number Census and its quality assurance: a review. Research briefing 6.03. • Simpson, L (2007) Fixing the population: from census to population estimate. Environment and planning series A, vol 39, 1045-1057. • Simpson, L and Brown M (2008) Census fieldwork: the bedrock of research for a decade. Environment and Planning series A.
June 2009
32 Memorandum from the Royal Statistical Society (OSC 07)
Summary
1. The Royal Statistical Society (RSS) has followed the process of the 2011 censuses closely establishing a Census Study Group in 2006. This has kept in close contact with the responsible statistical bodies and held a number of meetings, most recently on June 1st this year.
2. It is self-evident that the Census is a vital source of information. It is also clear that the 2011 censuses will be the most challenging and complex to date due to the increasing flexibility and diversity of the UK population and the growing need for information.
3. RSS views are as follows:
• We view positively the progress made to date on the methodology and procedures to be used in the census, the preparation that has been made to ensure both a high response rate and accurate information and the plans for intensive targeting of difficult areas.
• Procedures to be used for validation and the imputation of missing values and returns appear to be well thought through.
• We have more concerns over the adequacy of outputs that will be generated. In particular, funding for a significant part of the outputs work has not yet been secured in England and Wales (nor, we believe, in Scotland or Northern Ireland). Full value from the entire sums to be spent on the Census will not be obtained unless the quality of the outputs, which account for a relatively small part of the overall expenditure, is adequate. We hope that the Select Committee will follow this up and press for sufficient funding to be secured.
• Compared to 2001, substantial efforts are being made to ensure that there is more compatibility across the UK as a whole but full coherence will again remain elusive. In particular:
o Scotland will treat short-term residents differently and in a way that is incompatible with Eurostat requirements; its population will therefore not be determined on the same basis as the rest of the UK. This is a fundamental difference which will undermine compatibility throughout. o In contrast, we welcome GRO Scotland’s decision to include a question on income and regret that this will not be asked in England, Wales and Northern Ireland, thus preventing cross-UK comparison.
33 o It is important that the presentation of results and outputs are as coherent as possible between the different countries and obtainable from a single website.
• We are appalled that the address list being developed for England and Wales by the ONS in conjunction with Royal Mail, Ordnance Survey and local authorities’ National Land and Property Gazetteer will, as a result of copyright restrictions, only be available for the Census and will not be maintained thereafter. This is a colossal waste of public money. We hope Parliament will put further pressure on the three organisations and the ONS to develop a solution to ensure that the list will become a permanent maintained address register. Scotland and Northern Ireland have achieved much more than England and Wales in this area.
Detailed points
The Royal Statistical Society
4. The Royal Statistical Society (RSS) is the UK’s only professional and learned society devoted to the interests of statistics and statisticians. Founded in 1834 it is also one of the most influential and prestigious statistical societies in the world. The Society has members in over 50 countries worldwide and is active in a wide range of areas both directly and indirectly pertaining to the study and application of statistics. It aims to promote public understanding of statistics and provide professional support to users of statistics and to statisticians.
5. The role of statistics in monitoring the economic and social conditions of the nation and their use in public policy has been a concern of the Society since its earliest days. Improving the framework within which official statistics are produced has been one of its major objectives for the past 20 years or so. It has engaged actively in the process of reform undertaken by the current government setting up a National Statistics Working Party in the late 1990s and publishing its “Vision for National Statistics” in 2002 (revised 2005). It played a particularly active role in the consultation, discussions and legislative process that led to the Statistics and Registration Service Act and was pleased to see that a number of its proposed amendments to the initial Bill were reflected in the final Act.
6. The Society numbers many current and former official statisticians from many countries and from international organisations among its members.
Introduction
7. The RSS has followed the progress of the 2011 censuses closely. It established a Census Study Group in 2006 which aims to draw together the Society’s census
34 interests in the run-up to 2011. The group aims to contribute primarily in matters of census methodology and to address topics which are of broad cross-sectoral relevance to the census user community. It has kept in close contact with the statistical bodies responsible for the censuses and has held a number of meetings on relevant issues. On June 1st this year it held a major meeting: “2011 Census: Producing the Numbers” at which speakers from the Office for National Statistics (ONS), the General Register Office for Scotland (GRO Scotland) and the Northern Ireland Statistics and Research Agency (NISRA) presented papers and discussed progress with members.
8. It is self-evident that the 2011 Census is a vital source of information. The White Paper for England and Wales “Helping to shape tomorrow” highlights its value in shaping government policy, the allocation of resources by government, its importance to commercial companies, and to academic researchers. Moreover, the Census also accounts for a considerable proportion of expenditure on official statistics.
9. The 2011 censuses will be the most complex and challenging so far carried out. The UK population has become yet more flexible and diverse, making the delivery of accurate data more difficult, at the same time as the need for information has become greater.
Procedures and methodology
10. The RSS views positively the progress made to date on the methodology and procedures to be used in the 2011 Census. It is pleased to see the extent of preparation that has been made to ensure both a high response rate and accurate information. Lessons have clearly been learned from the 2001 census, a number of technical issues have been addressed, and practical changes have been decided to the procedures used to collect the data. We welcome the plan to use the field force flexibly so that unexpected problems can be followed up and the care being taken to ensure that difficult areas will be particularly targeted.
11. The use of post-out and post-back together with the option of on-line returns for the majority of addresses in England, Wales and Northern Ireland makes the entire operation more sensitive than before to the quality of the address pre-listing. The advantage of reducing costs and, importantly, freeing up additional resources to be directed at difficult areas is welcomed, but sufficient evidence has not yet been published to demonstrate that the address lists in England and Wales from the Post Office, Ordnance Survey, and local authorities’ National Land and Property Gazetteer can be reconciled with sufficient confidence to ensure the necessary levels of coverage and reliability. Given the highly public failings of address listing in some local authorities in 2001, very convincing evidence must be provided regarding the quality of the address base if potential damage to the 2011 census population estimates is to be avoided. (See also paragraph 20.)
35 12. The procedures to be used for validation, and the imputation of missing values and returns, appear to be well thought-through. There are potential errors to be introduced by not matching all UK-based visitors back to their home addresses and as a result of “mode bias” arising from the use of parallel paper and internet questionnaires but these are among the areas identified by the ONS as requiring further work.
13. It goes without saying that intensive cooperation is needed between the ONS and local authorities in difficult-to-target areas before, during and after the count. Much effort has already been directed here but it is crucial that it is maintained by both parties.
Outputs
14. The ONS is currently planning a consultation on the outputs from the census, to commence in summer 2009. At the moment, we have some concerns as to whether this area of the project will receive sufficient attention and resources:
• A significant part of the work of generating outputs will take place after the current 5-year funding programme for the Office for National Statistics ends in March 2012. Funding for this is therefore not secured. The Census White Paper for England and Wales published in December 2008 estimated the total cost of the 2011 Census in England and Wales over the period 2005-2016 to be £482 million of which £450m has been secured.
• Since generating outputs is the last part of the Census process, there is in any event a risk that money available will be squeezed if contingencies arise elsewhere – this is a very major concern to the user community. It must be emphasized that the value of the census to users is in large part determined by the quality of outputs, regardless of the far greater sums expended on enumeration and processing.
• In 2001 only 3% of the census budget in England and Wales was spent on outputs; users do not believe that the potential benefits of the uniquely rich source of information were maximised.
• Communication and presentation of outputs generally is one of the weaker parts of the UK statistical system.
• It is imperative that once consultation on census outputs is completed, late changes are avoided: 2001 outputs were considerably damaged by late changes regarding disclosure control which undermined much of the prior consultation and degraded the utility of some census outputs to the point that they have been little used (particularly travel to work and migration statistics).
36 15. In summary, there seems to us to be a risk, at least at present, that the provision of outputs may not prove to be adequate. This would significantly reduce the effective benefits of the Census and mean that full value would not be obtained from the considerable sums spent on the rest of the process. Some of our concerns may, of course, be assuaged once the current consultation process has run its course but we suspect that funding will remain uncertain or that adequate funding will only appear at the expense of other ONS work.
16. We hope therefore that the Select Committee will follow this aspect up in due course and press for sufficient funding to be forthcoming. Funding must also be sufficient in Scotland and in Northern Ireland not just to ensure that their outputs are adequate but also to ensure that those for the United Kingdom as a whole are.19
UK coherence
17. Compared to 2001, substantial efforts are being made to ensure that there is more compatibility between the censuses in the different countries of the UK and this is welcome. Nevertheless full compatibility will remain elusive. We are resigned to the fact that not all questions will be the same in the different countries. In England, Wales and Northern Ireland, information on Intended length of stay will be used to remove short-term UK residents. However in Scotland, a full questionnaire will be collected from everyone residing or intending to reside in the UK for a period of six months or more and the equivalent question about intention to stay will not be asked. It will therefore not be possible to directly determine the population on the same basis. This is a fundamental difference which will undermine compatibility throughout, particularly given the increased importance of migrant workers and other visitors. We note also that the Scottish approach will be inconsistent with Eurostat requirements thus undermining intra-European compatibility; we feel this infringes the spirit of the Concordat on Statistics in the Devolution Memorandum of Understanding (para E10.3.2 of the Memorandum).
18. However, we strongly welcome GRO Scotland’s decision to include a question on income for the first time, and regret that ONS and NISRA are not planning to do the same, which would enable comparison of this topic, which is so important to users in all sectors, across the UK as a whole. We believe that the ONS and NISRA should actively investigate the use of HMRC and other date sources to estimate incomes to compensate for this omission.
19 “Scotland’s Census 2011 – A Government Statement” was published in December 2008. It estimates the cost from 2005-13 as £65 million. A budget of £39.6 million has been allocated to fund the Census up to Census day. Provision for later years will be subject to future spending reviews. The publication of plans for Northern Ireland is awaited, but an answer to a Written Question in the Northern Ireland Assembly stated that the cost was expected to be £21.5 million between 2008/9 and 2013/14.
37 19. It is important that the presentation of results and outputs are as coherent as possible between the different countries – for example that the design, content and numbering of outputs are similar, and that outputs for all countries can be obtained from a single website.
Address lists in England and Wales
20. The ONS is working with Royal Mail, Ordnance Survey and local authorities’ National Land and Property Gazetteer to create a full address list for England and Wales (see para 11). However, copyright restrictions by the three organisations mean that this list will only be used for Census purposes, and not be maintained thereafter. This is a colossal waste of public money and has already been criticised by the Treasury sub-Committee’s 2008 report Counting the Population. We hope that Parliament will add to pressure on the three organisations and ONS to develop a solution which will enable the list to become a definitive national address register, used for many purposes by many organisations, and maintained in the future. In this respect Scotland and Northern Ireland have already achieved much more than England and Wales and consequently have a much stronger basis for the creation of their census address lists.
June 2009
38
Memorandum from the Demographics User Group (OSC 08)
Executive Summary
1. The Demographics User Group (DUG) represents the views of 11 commercial companies – Abbey, Barclays, Boots, Co-operative Group, E.ON, John Lewis, Marks & Spencer, Sainsbury’s, Tesco, The Children’s Mutual, and Whitbread – which make extensive use of the Census statistics produced by government. Commercial companies, like government bodies, need reliable population statistics when making investment decisions which total many billions of pounds each year.
2. Members of DUG believe that in general good progress is being made toward the 2011 Census, but wish to highlight the following issues for attention:
• The new definitive address register should be made publicly available in the national interest, and updated – not treated as a one-off for the Census. • The danger that the remaining £32m funding yet to be voted might be cut, to the disproportionate detriment of the ultimate statistical outputs. • If, unlike Scotland, a question on income is not to be included, the ONS should put immediate effort into using other data sources, such as HMRC records, to estimate individual incomes, and include this in the Census database. • The ONS is right to now be shifting its focus to planning for statistical outputs, and meeting users’ needs. In particular: - An adequate budget for creating statistical outputs (c.f. just 3% of the total budget in 2001). - Repeat the success of the 2001 Census by making statistics free at the point of use, with simple Click/Use licensing, to encourage maximum use by all sectors – government, commerce, academia, and the general public. - Accompanying products, such as map boundaries and postcode directories, should also be freely available, to maximise the use of the Census and the return on the investment. - The Registrars’ General policy of producing statistics which are as compatible as possible across all four countries of the United Kingdom now needs detailed planning.
Timeliness
3. The Census White Paper “Helping to shape tomorrow” published in December 2008 provides a good checklist against which to assess the ONS’s progress. We are reassured that considerable thought has already gone into planning the address register, targeting fieldwork, processing, imputing missing information to produce the best possible estimates, quality assurance, and devising better methods of preventing disclosure of information about identifiable individuals than were used in 2001. The
39 Test Census was carried out successfully in 2007, and preparation for the rehearsal this autumn appears to be on course.
4. It is, however, the ultimate statistical outputs that are of paramount interest to users, and it is essential that the ONS proceeds with its plans for publishing strategic proposals this summer as a prelude to detailed dialogue with users / customers in the next year. We highlight several important aspects in paragraph 14 below.
Cost-effectiveness
5. When deciding how best to invest many £billions to meet the needs of local consumers, companies seek recent and accurate statistics for small areas for both resident populations and workplace populations. The 2001 Census still forms the bedrock for such decision-making. It is recognised that the Census coverage was inadequate in a small number of local authorities, but this has not prevented heavy use of the data as the best available source. However, the results are now more than eight years old, and some parts of the country have experienced rapid change. Inaccurate statistics inevitably result in bad investment decisions.
6. The Census White Paper estimates the total cost of the 2011 Census in England and Wales over the period 2005-2016 to be £482 million. Provision of £450 million of the cost has been made up to the period 2011-12; provision for later years will be subject to future spending reviews.
7. We believe that the money being spent on the Census is an excellent investment. A lack of reliable information for small areas would result in flawed decisions and the misallocation of massive expenditure every year by both government bodies and commercial companies. We also think that the ONS is spending the money wisely, and are especially pleased at the new emphasis on targeting fieldwork at particularly difficult areas and types of populations in order to increase response rates. We do, however, have two major concerns:
8. Firstly, the new address register cannot be used for any other purposes. The ONS is currently compiling a special address register for the 2011 Census in England and Wales, buying information from the Post Office, Ordnance Survey, and the Local Government Information House at an estimated cost of £12m. However, due to these three public bodies each defending their own intellectual property, this definitive register will not be available for any other purposes, not even within the ONS, let alone other public bodies or the wider economy; nor will it be updated. This failure of public bodies to operate for the public good in England and Wales is scandalous, and in sharp contrast to Scotland, where a national address register is being created.
9. The Chair of the UK Statistics Authority, in a reply (26 February 2009) to a letter from the President of the Royal Statistical Society stated: “We agree that the issue needs to be tackled with vigour. Although the ONS is preparing the address
40 information it needs for the Census, the longer term solution is likely to lie with some or all of the other bodies you mention. We believe that a single address register will be an important component in the delivery of many government objectives, and we will do all we can to encourage Ministers to take forward for the longer term the development work that the ONS is currently undertaking.” It would be a great achievement if your Committee could finally stop public bodies vying over intellectual property, and allow this new definitive address register to be generally used in the national interest.
10. Secondly, the remaining £32m is yet to be voted for the period 2012-2016. We are fearful that this might be cut, to the disproportionate detriment of the ultimate outputs. For the 2001 Census, only 3% of the budget was spent on creating statistical outputs, which are of course the sole purpose of the project. There is a real danger that, having carried out a good Census data collection, the ONS will fail in the last hundred yards to maximise the valuable statistical information that should be produced.
Reliability
11. DUG members fully appreciate that many changes in society – such as more migration, weekly commuting, and more entry phones – make it increasingly difficult to assemble reliable information about the population using traditional methods such as the decennial Census. We believe that the ONS is putting every effort into maximising the reliability of the 2011 Census in what are difficult circumstances. The ONS is also right in simultaneously investigating the potential of administrative sources as recommended in the Treasury Sub Committee’s Report “Counting the Population”: these will need to be compared with Census counts in 2011, and should provide the foundation for tracking population changes in the following decade.
Relevance
12. We are pleased to see new questions on second residence and language included in this Census. However, our great regret is the ONS’ intention not to ask a question on income. This topic is important to users in all sectors. Income is included in Censuses held in many other countries, and will be asked in Scotland in 2011 for the first time. If a question on income is not to be included, the ONS should put immediate effort into using other data sources such as HMRC records to estimate incomes, and include this in the Census database.
13. Conversely, we doubt the relevance, reliability, and value of several new questions which were added at the behest of government departments after the open consultation with all users on priorities had been concluded: National identity; Citizenship; Month & year of entry; Intention to stay; and Number of bedrooms.
Usefulness
41
14. In order to maximise the value of the investment in the Census, we believe that the forthcoming plans for statistical outputs should include the following:
• An adequate budget for outputs. If this were increased from the remarkably low 3% in 2001 to say 4-5%, this would still amount to only £19m-£24m of the total budget of £482m. • Repeat the success of the 2001 Census by making statistics free at the point of use, with very simple Click/Use licensing: this greatly increased the use made of the information collected at public expense by all sectors – government, commerce, academia, and the general public. • Accompanying products, such as map boundaries and postcode directories, should also be freely available, notwithstanding any intellectual property claims by Ordnance Survey and Royal Mail, to maximise the use and the return on the investment. • The Registrars’ General policy of producing statistics which are as compatible as possible across all four countries of the United Kingdom needs detailed planning on the comparability of questions, the design of common tables, and availability of all statistics from a single website.
June 2009
42
Memorandum from the Market Research Society (OSC 09)
EXECUTIVE SUMMARY
The Market Research Society and the Private Sector User Community
(1) The Market Research Society (MRS) and the MRS Census and Geodemographics Group represent market and social researchers and geodemographers; professionals who collect and analyse geographical and statistical information.
(2) The UK Census of Population is a key element underlying the private sector provision of demographic services to a wide range of organisations in both public and private sectors. Its comprehensive nature, accuracy and open availability via these routes lead to significant social and economic benefits within the UK.
The 2011 Census: Overview
(3) The operation of the 2011 census will face increased challenges arising from an increasingly difficult to count population and from higher expectations of accuracy and access. We believe that in the main the census agencies are well placed and on schedule to meet these challenges. In particular we welcome:
• The commitment of the Registrars General to UK harmonisation of the censuses. • The inclusion of a fourth page in the census questionnaire which has allowed the retention and addition of key questions. • The aim stated by the Registrars General of access to census data which is free at the point of delivery.
The 2011 Census: Challenges
(4) We believe that, for us, the most important outstanding questions on the census operation concern the following areas:
• The outstanding requirement for additional funding to allow outputs to be produced, to provide modern facilities for end users to access the data, and to meet the stated objective of making output free at the point of delivery. • The delay in reaching a final agreement with Ordnance Survey to enable the use of the combined address register and the future free use of the of the Census data, particularly the Census output geography. • There is as yet no timetable for publication of results, and in particular no target date for publication of detailed statistics for small areas.
43 • There remains uncertainty about the quality and completeness of coverage of the combined address register which will be used to post out forms and to guide manual enumeration in difficult areas. • Methods of Statistical Disclosure Control, upon which the design and production of outputs depends, have not yet been finalised.
(5) Announcements on the evaluation of the combined address register and on methods for statistical disclosure control are expected in the near future, and we hope that these announcements will fully cover questions outstanding in these areas.
DETAILED SUBMISSION
The Market Research Society and the Census and Geodemographics Group
(6) The Market Research Society (MRS) is the world’s largest association representing providers and users of market, social, and opinion research. The UK is the second largest market in the world for these research services. Full details about MRS and its activities are available at: http://www.mrs.org.uk
(7) Geodemographics can be defined broadly as ‘the analysis of people by where they live’, and involves analysing demographic data within small geographical areas to serve a wide range of clients in the public and private sectors. The annual turnover of geodemographic activities in the UK has been estimated at £200m. The Census and Geodemographics Group (CGG) is an MRS advisory board, founded in 1989 to represent the interests of this important activity. The CGG has specialists in market research, retail site location, market and database analysis, as well as census distributors and academic researchers.
(8) The CGG is involved with Census developments through representation on the ONS Business and Professional Interests Advisory Group, and with wider matters through membership of the Statistics User Forum as well as through an extensive network of contact in the market research industry.
UK harmonisation of the censuses
(9) The Registrars General have agreed that they will ‘will work together and will reach mutual agreement wherever possible…. which will facilitate harmonisation where that is in the interest of Census users’ [1]. This commitment is welcome to all who work with census data across the breadth of the UK. While there is expected to be a high level of consistency in census results across the UK as a result of these efforts there remain a number of significant areas in which the methods or questions are not consistent across the UK, most notably some differences in the questions used to derive the basic population base. While it is inevitable that differing requirements and considerations in various parts of the UK will inevitably lead to some departures from
44 complete consistency, there are many census users for whom UK consistency is highly desirable.
The inclusion of a fourth page in the census questionnaire
(10) The approval of funds for the fourth page of individual questions in the census questionnaire has allowed the retention of a number of key questions, in particular on industry, travel to work, level of qualifications, size of establishment and hours worked. The planned addition of a further question on second residence will also be of value.
(11) The omission of a question on income from the England and Wales census is however disappointing to many in the user community.
Open access to census data
(12) The economic and social case for open access to census data has been supported by a number of government studies and papers. See, for example, [2], which was instrumental in the creation of ‘click-use’ licenses for access to the 2001 census data. The advent of click-use licenses together with on-line access to 2001 census data has made the data available to a much wider range of users, and for a greater range of applications.
(13) We believe that continuation of the policy of making census data free at point of use, an objective stated in the agreement of the Registrars General [1], is highly desirable in order to maintain the benefits already seen from these developments in 2001.
The combined address register
(14) The use of post-out methods based upon the construction of a combined address register is a significant innovation in methodology for the 2011 census. Any such innovation has, prudently, to be viewed as a potential source of risk for the operation of the census and to the quality of results which can be obtained.
(15) The key milestones for census users in this respect are firstly, the expected publication by ONS of their assessment of the quality of the combined address register and its various components, and secondly the results of the quality assessment of the census rehearsal to be conducted later in 2009.
Funding to allow outputs to be produced
(16) We understand that funding for all output requirements for the census is not yet assured, and we urge the ONS and the Committee to work together to secure funding
45 that will allow a wide range of statistics, including statistics for small areas, to be made available to the public.
Agreement with Ordnance Survey
(17) A persistent difficulty which census users, and particularly census distributors, have encountered with the 2001 census data is the nature of the control which Ordnance Survey has retained over the distribution of the boundaries for statistical areas.
(18) While this has allowed end users to get copies of the boundaries free of charge, it has restricted the redistribution of boundaries as part of a value added product. Value added redistribution is a natural part of the market in information, and the asymmetric nature of the conditions associated with these boundaries limits the efficiency of these markets. A further issue relates to current time limits on the license to the boundaries which may prevent their continued use into the future.
(19) We hope that continued access to 2001 census boundaries can be ensured into the future and that more open access to 2011 census area boundaries can be established.
Statistical Disclosure Control
(20) The ONS has undertaken considerable research into methods for statistical disclosure control and the protection of the confidentiality of individuals, but the results of this research have not yet been published. As a consequence there has as yet been no opportunity for many users of census data to assess how they would be affected by any proposed methods.
(21) While the ONS’ schedule in this respect is, we understand, on time, it should be observed that this area has historically been troublesome in the production of census statistics. There were, for example, delays in the production of 2001 census data resulting from late changes to the confidentiality criteria applied. These had knock-on effects on the disclosure control methods used, which in turn affected outputs.
(22) The ONS plan to publish more details of their proposed methods this year, and we hope that these will provide a basis for disclosure control methods which have the confidence of the ONS, of those representing the interests of census respondents, and of census users.
Timetable of publication of results
(23) Timely publication of census results is of importance to many users of census data. Typically the publication of a new census allows great improvement in the accuracy and effectiveness of a wide range of research and demographic activities. The
46 earlier the census data can be published, the earlier these benefits accrue and the greater the total benefits obtained.
(24) At present there is, to the best of our knowledge, no firm timetable for the publication of census statistics other than an indication that the core small area statistics may be expected sometime during 2013.
(25) We would greatly welcome more detail on the planned timetable for publication of statistics, and more so if these statistics can be published earlier than we are currently expecting.
References
[1] The Conduct Of The 2011 Censuses In The UK Statement Of Agreement Of The National Statistician And The Registrars General For Scotland And Northern Ireland at http://www.ons.gov.uk/census/2011-census/2011-census-project/index.html
[2] Cross Cutting Review of the Knowledge Economy. HM Treasury (2000) at http://www.hm-treasury.gov.uk/spend_sr00_ccr.htm
June 2009
47 Memorandum from the Equality and Human Rights Commission (OSC 10)
Who we are and what we do 1. The Equality and Human Rights Commission (EHRC) was established on 1 October 2007 and is working to eliminate discrimination and hatred of, prejudice and hostility against different groups, reduce inequality, protect human rights and to build good relations, ensuring that everyone has a fair chance to participate in society.
2. The Commission is a non-departmental public body (NDPB) established under the Equality Act 2006 and is accountable for its public funds, but independent of Government.
Summary
3. This submission is in relation to the aspect of the PASC inquiry that is considering whether the census process will produce sufficiently reliable, relevant and useful information. There are three key points made:
• The inclusion of a sexual orientation question is important in making the census relevant and useful in relation to equalities legislation and it is possible for the data to be sufficiently reliable.
• The religion question must not be a leading question in terms of assuming a religion and must cover belief as well as religion in line with equalities legislation in order to make the information reliable and useful.
• A second disability question in line with the Scottish census is necessary for this information to be reliable and useful.
An explanation of these points has been provided below.
4. Inclusion of a sexual orientation question is important for the census to be relevant. In the consultations undertaken by the Office for National Statistics (ONS) on the content of the 2011 census, high user demand from stakeholders placed sexual orientation in the highest category of need. In relation to the importance of this in making the census relevant and useful we would stress in particular:
48 5. New legislation is increasing the demand for data on sexual orientation to meet information needs of public sector duties and equality monitoring generally. The Equality Bill currently going through Parliament is expected to increase demand substantially for baseline data on the Lesbian, Gay and Bisexual (LBG) population in order to support the information needs of public bodies who will have to comply with much broader public sector duties to promote equality. This includes bodies operating at a local level, where the census would be the only source of sufficient information, even if sexual orientation data is collected on large national surveys in the future.
6. LGB individuals should have the opportunity to identify themselves in the census to the same extent as other groups covered by equalities legislation. For the census to be fully relevant it needs to give equal treatment to this equality strand as to the others, all of which are covered in the census. Inclusion on the census would also help establish the general acceptability of collecting data on this topic.
7. An on-line survey20 of nearly 3,000 people with minority sexual orientations suggests that high proportions of these respondents segregate themselves into particular areas or occupations because of fears that their sexual orientation will not be accepted in some places. This is potentially damaging for individuals and the economy and these patterns need to be better understood to help guide local services and interventions. Only the census will deliver this.
8. Inclusion of a sexual orientation question will yield sufficiently reliable data. The Commission has been arguing for the inclusion of a question on this topic for over a year and still believes that it is appropriate and possible to include one on a voluntary basis in the same way as the question on religion is included. The Sexual Identity Project carried out by ONS has demonstrated that it is possible to collect data on this topic and has in the process developed a question that could be used.
9. Although a minority of people may identify differently in the census process than they might in surveys where responses are more private, research suggests this is a relatively small minority and the data on those identifying with minority sexual orientations within the household that the census would deliver would be valuable in its own right. It should be noted that similar issues of accuracy or privacy could equally apply to other questions such as the
20 This will be published next month but the EHRC can provide the Committee with details if required.
49 disability or religious ones, but are not seen as a barrier to their inclusion in the census.
10. Ensuring that the religion question is not a ‘leading’ question that creates a bias against non-religious beliefs in order that the data are reliable. Equalities legislation is framed in such as way as to be concerned with both religious and non-religious beliefs. The Commission therefore sees an urgent need for the religion question to be reworded so that it is no longer a leading question and to ensure that it is not biased against non-religious beliefs and those with no religion. Concerns have been raised by stakeholders that the current question is leading and this argument is supported by survey data which shows that phrasing the question differently can result in a much higher percentage with no religion. The census question should also be clearer that non-religious beliefs may be reported, e.g. by changing the wording of the last category to "Any other religion or belief, write in" and also the first category to "No religion or belief"
11. The Commission sees a strong need for a second question on disability, in line with the two questions proposed in Scotland. The proposal for Scotland involves asking a question about specific health conditions, such as mental health and specific impairments such as being deaf and then asking the general question proposed in the England and Wales census on whether the respondent has a limiting health condition or disability. Inclusion of the prior question as proposed for Scotland is necessary for both reasons of reliability and relevance/usefulness.
12. In respect of reliability, research suggests that some areas, such as mental health, are under-reported in general questions on disability/health conditions (particularly as the proposed question does not explicitly indicate that it covers both physical and mental health conditions and disabilities). In terms of relevance and usefulness it is clear that the issues and support requirements of, say, deaf people, are substantially different from, say, people with mental health conditions. Failure to distinguish different disabilities at this level make the relevance of the census data very poor for local service provision or for helping local authorities to prioritise activities within the duties laid on them by equalities legislation.
June 2009
50 Memorandum from Dr Oliver Duke-Williams (OSC 11)
Summary
• The proposals for the 2011 Census in England and Wales include a number of new questions relating to migration and mobility • The new question on month and year of entry to the UK is sensible and welcome
• The new question on use of second residences is a good innovation that represents methodological confidence and is welcome • The new question on length of intended stay in the UK is problematic. The results may be of poor quality, and the question may harm general response to the Census. The submission advises dropping this proposed question
Background
1. This submission is made by Dr Oliver Duke-Williams, of the School of Geography, University of Leeds. Dr Duke-Williams is the Deputy Director of the Centre for Interaction Data Estimation and Research (CIDER) and the co- ordinator of the Census Data Feed Research Network (CDFRN).
1.1. CIDER is a data dissemination unit funded by the Economic and Social Research Council (ESRC) Census Programme 2006-2011; it provides access to detailed migration and commuting flow data sets to the UK academic community.
1.2. The CDFRN is funded by the ESRC Census Innovation Programme, and acts to co-ordinate a number of active and interested researchers studying the potential for new models of dissemination of census results and the implications of replacing existing dissemination models.
2. The author of this submission had previous experience of involvement in the preparations for the taking of the 2001 census and the production and dissemination of results of the 2001 census, through involvement in the ONS
51 Output Working Group. The author is currently a member of the ONS Census Web Services Working Group (CWSWG) and represents CIDER at the ONS 2011 Output Working Group.
3. The operation of the census in this country has generally been successful in the past. Newspaper reports on under-enumeration (‘the missing million’) in previous Censuses may suggest problems, yet it remains the case that general levels of compliance are high and levels of error are low. Specific problems have occurred in the past, for example enumeration problems in Manchester and Westminster in the 2001 Census, and future methodology should expect to account for similar issues.
4. A number of issues and developments in this decade have affected potential census response, and expectations of data availability.
4.1. Widely reported incidents of data loss by government ministries and agencies have damaged the reputation of these bodies with respect to their ability to handle sensitive personal data.
4.2. There has been a growth in popular concern about the so-called ‘surveillance society’ or ‘database state’ and the extent to which personal data are gathered and stored.
4.3. At the same time, the growth in ‘e-enablement’ of government services has led to increased use of the Internet as a medium of communication between citizens and government.
4.4. In recent years there has been increasing pressure for government agencies to make available those data that have been gathered at the tax-payers expense, especially data from Ordnance Survey. This has led to increased expectation of easy access to accurate data.
52 Scope of comments
5. The submission comments on the potential for the results to provide ‘information about the population which is sufficiently reliable, relevant and useful’. In particular, it focuses on proposed questions in the 2011 Census that focus on migration and mobility.
6. PASC has a specific remit to address the conduct of the 2011 Census in England and Wales. This submission is largely concerned with the preparations of the ONS for this census, but also makes reference and draws comparison to the preparations of the General Register Office (Scotland) for the 2011 Census of Population in Scotland where relevant. This is considered appropriate because of the somewhat unique nature of migration as a phenomenon that has a ‘double geography’, namely an origin and a destination. Internal migration flows can and do take place between the member countries of the UK, and thus the creation of consistent data sets requires close collaboration between ONS, GROS and the Northern Ireland Statistics and Research Agency (NISRA).
Questions about migration, mobility and identity
7. Questions about migration and other aspects of mobility have appeared in various forms in British Censuses since 1841. In recent censuses (1961 onwards) migration (both internationally and within the UK) has been monitored directly with a question that asks each individual to state whether or not their place of usual residence one year ago was the same as their usual residence at the time of the census. If it was not, then the individual is prompted to give a full UK address or the name of a foreign country. Persons are thus characterised as ‘migrants’ if they had changed their usual residence within the year prior to the census.
8. The decennial Census is our main source of detailed migration data that include substantial socio-demographic content. Alternative sources exist in the form of administrative records from the NHS but these carry little detail about the individuals concerned, and there is no sensible way to expand them in this
53 capacity. Migration occurs at too fine-grained a scale to successfully capture in sample surveys. It is therefore important that the Census continues to generate fit-for-purpose migration data for both large and small geographic areas.
9. Earlier censuses asked individuals to state (with varying levels of precision) their birthplace. Comparison of birthplace information with the area of current residence permitted ‘lifetime’ migration patterns to be studied. This formed the basis of influential migration research in the Victorian era. Limitations in the use of a simple ‘birthplace’ question have been amongst the motivating factors in the inclusion of further questions that seek to establish a persons ‘identity’. These include nationality (regularly asked), parent’s country of birth (asked in 1971) and ethnic group (asked since 1991).
10. The optional question on religion (asked in 2001) - whilst having additional motivations for its inclusion - also produced results that characterise important aspects of personal or cultural identity.
11. The 2008 White Paper proposes a number of new questions relating to migration, mobility and identity. These are addressed here using questions forms included either in the 2008 White Paper (Cabinet Office, 2008) and/or the 2009 Census Test (ONS, 2009).
‘Year of arrival’ question
12. Question 8 on the 2009 Census Test Questionnaire asks “If you were not born in the United Kingdom, when did you most recently arrive to live here?” Respondents are asked not to count short visits away from the UK, and invited to give a year and month.
13. The topic ‘year of arrival’ for those born outside the country is identified as a core topic for inclusion in national censuses in the UN Census guidelines (United Nations, 2008), which seek to provide a framework for statistical agencies around the world so as to facilitate the production of robust comparable statistics.
54 14. This question is ‘new’ for the 2011 Census in this country. A similar question was asked in the 1971 Census, although on that occasion it was focussed on the year of first arrival, but it has not otherwise been included in British Censuses.
15. Hattersley and Creeser (1995) note that response to this question in 1971 was problematic, with confusion arising in interpreting ‘first entry’ to the country, and that there was ‘a strong relationship between errors and year of entry to the UK’.
16. Inclusion of the month of arrival is only really relevant for short term migrants, and is likely to suffer from recall error for longer term migrants. However, any change to the question would risk making the wording unnecessarily complex.
17. Despite these concerns, the question is to be welcomed, as there are many significant issues over social inclusion, employment opportunities, educational attainment etc. that may be related to length of residence in the UK that could not otherwise easily be explored.
‘Intention to stay’ question
18. The ‘year of arrival’ question is followed by two additional questions directed at those born outside the UK. The first of these (Question 9 on the 2009 Census Test Questionnaire) separately identifies those who have arrived within the year preceding the census, and directs them to a supplementary question (Question 10). Those who arrived more than one year ago are directed on to Question 11, which applies to all persons.
19. Question 10 thus applies only to persons born outside the UK who have recently arrived; it asks about their length of intended stay in the UK. Possible answers include less than 6 months, 6-12 months, and more than 12 months.
20. This question is unlike most other census questions, in that it is subjective: it solicits an opinion rather than facts such as age, occupation or ethnic group that are objectively true at the time of response.
55 21. To a limited extent there are other census questions that are subjective, for example those about (self-reported) level of general health. However, the general health question requests a retrospective opinion, whilst intention to stay is prospectively subjective - it may change in the future for a variety of reasons such as the formation or dissolution of a relationship, success or lack thereof in the employment market and so on.
22. It is the opinion of the author that this question will not yield results that are “reliable, relevant and useful”. 22.1. The population to whom it applies have perhaps the greatest reason to be suspicious that their answers may be passed on to other government departments. 22.2. For visitors to the UK who require a visa to enter the country, it seems unlikely that many (if any) would answer in a manner which is inconsistent with the terms of their entry visa, regardless of any actual intention to stay for a longer period. For this reason, it may be the case that the UK Border Agency’s statistics on visa issuance would be no less reliable than any data gathered from this census question. 23. It is noted that an equivalent question was considered for inclusion by GRO(S) in the 2011 Census in Scotland. The Scottish Government Statement on plans for the 2011 Census (Scottish Government, 2008) not that the question was not planned for inclusion due to its subjective and complex nature, ‘raising concerns about the quality of data it would yield’.
24. It is a commonly accepted principle of Census methodology that specific questions that individuals find objectionable may have a detrimental effect on response to the census as a whole. For example, this is one of the main reservations about the inclusion of a question regarding personal or household income.
25. It is the opinion of the author that the question on length of intended stay in the UK may be considered invasive and appears accusatory. As well as the potential to
56 generate poor quality data in specific response to this question, it may harm the quality of data gathered from other questions.
26. Inclusion of this question may harm response from the target group (those born outside the UK who have lived in the country for less than 12 months), on the grounds that it appears to be an example of the authorities ‘checking up’ on them. Accurate counting of recent migrants is vital to efficient targeting of appropriate services by local and national government, and thus efforts should be made to promote – rather than deter – completion of the Census.
27. The question may also be considered unsuitable by the general media, and could thus lead to negative portrayal of the wider census process in the popular media. This could harm response from a wider population.
28. The author is not aware of a similar question in any other national census. The closest comparable questions are those posed in specific census forms for emigrants from Georgia and from FYR Macedonia: in these cases some questions are asked of emigrants about their intentions to return to their home country. However, this approach seems very different in intent to the proposed ‘intention to stay’ question.
Second residences
29. A new pair of questions have been proposed that ask about the usage of second residences, for a variety of purposes including working away from home, armed forces bases, separate parents/guardians and holiday homes etc. The first of these questions asks for reasons that a second residence is used, whilst the second question asks for the address of a second residence. 30. Whilst there is considerable media interest and anecdotal evidence about second residences, there is currently little consistent data about them, especially at a national level. These questions are therefore welcomed and it is expected that they will render very useful information. 31. The questions are innovative, and should be welcomed as evidence of strong methodological development on the part of the ONS. A question on second
57 dwellings was included in the Spanish Census of 2001, in a simpler form which asked about the use of a second dwelling, and if so whether it was in the same province or municipality. A number of censuses in other countries (e.g. Austria 2001, Belgium 2001) have addressed the issue of second residences in part, by allowing respondents to identify an alternative address (i.e. other than the address at which they are completing the census) from which they normally depart for work. However, the use of a second residence for work purposes is only one part of a much more complex set of possible circumstances. The proposed questions in England and Wales should allow exploration of these issues with a higher degree of subtlety than is possible from the partial approaches used in some other countries. 32. Simple innovation alone is not sufficient justification for the inclusion of a question in the census: there must also be a demonstrable need for the results, and an expectation of good quality response. It is the opinion of this author that both of these criteria are met by the proposed questions on second residences.
Direct one-year migration question
33. A direct one-year migration question is proposed with similar wording to that used in all censuses from 1961 onwards. Previous censuses have produced important and useful data sets, and it is expected that this question will continue to produce useful results.
Recommendations
34. The following recommendations are made as a result of the above statement:
• The proposed new question on length of intended stay in the UK should be removed on the grounds that:
• It may have a harmful effect on overall response
• Those data which the question yields may not be accurate.
58 • There are legitimate reasons for exploring the length of time that visitors may stay in the UK, especially those who come here for employment. The issue is sensitive and it is recommended that the issue should be investigated using interview based sample surveys. • The proposed new question on month and year of arrival is a sensible one which should yield useful results, and its inclusion should be supported. • The ‘usual’ one-year migration question is important and should be retained.
• The proposed new questions on second residences are innovative, and their inclusion should be supported.
References
Cabinet Office (2008) Helping to shape tomorrow - The 2011 Census of Population and Housing in England and Wales, Cm 7513
Hattersley, L and Creeser R (1995) Longitudinal Study 1971-1991 History, organisation and quality of data, LS Series No. 7, London: HMSO, http://www.ons.gov.uk/about/who-we-are/our-services/longitudinal-study/resources- and-definitions/history--organisation-and-quality-of-data/index.html
Office for National Statistics (2009) 2009 Census Rehearsal Questionnaire, Household Form H1, http://www.ons.gov.uk/census/2011-census/2011-census-questionnaire- content/2009-rehearsal-questionnaire--h1-.pdf
Scottish Government (2008) Scotland’s Census 2011 - A Government Statement, http://www.gro-scotland.gov.uk/census/censushm2011/policy-and- methodology/2011-census-gov-statement-and-supporting-docs/scotlands-census- 2011-a-government-statement.html
United Nations (2008) Principles and Recommendations for Population and Housing Censuses Revision 2, Department of Economic and Social Affairs, Statistics Division, Statistical papers Series M No. 67/Rev.2, http://unstats.un.org/unsd/demographic/sources/census/docs/P&R_Rev2.pdf
June 2009
59 Memorandum from the Electoral Commission (OSC 12)
Summary
• The Electoral Commission welcomes the proposals set out for the 2011 Census in Helping to shape tomorrow: The 2011 Census of Population and Housing in England and Wales.
• The Commission very strongly supports the inclusion of nationality questions in the next Census as nationality affects eligibly for inclusion on the electoral register. The Census for England and Wales includes a nationality question, but the General Register Office for Scotland (GROS) has not yet agreed to include a nationality question for the Census in Scotland.
• The Commission expects to work with the Office for National Statistics (ONS) and GROS in using the output to review the completeness of electoral registers. This should inform the Commission’s recommendation in 2014 about whether there should be a permanent move from household registration to individual electoral registration.
Background
1. The Electoral Commission reports on the accuracy and completeness of electoral registers. By accuracy, we mean that there are no false entries on an electoral register; and by completeness, we mean that every person who is entitled to have an entry in an electoral register is registered.
2. The Census is a very useful mechanism for monitoring the completeness of electoral registers. In 2004-05, the ONS conducted research for the Commission that entailed comparing the findings from the Census and the Labour Force Survey (to provide nationality data) with the electoral registers.
3. The findings from this research were published by the Commission in its report, Understanding electoral registration. This report has been a vital source of information about who is missing from the register and has enabled the Commission to target its campaigns and guidance accordingly.
Census 2011
4. The Commission will be looking to the ONS and GROS to conduct comparable research following the 2011 Census. We have taken a close interest in the progress of the Commission and have recently met with the Outputs Team to discuss the inclusion of nationality questions in the Census and the options and timings for any such research.
60 5. At present, the planned Census forms for Scotland do not include a nationality question. Whilst the Commission is aware of the competing demands for questions to be included on the Census forms, we hope that a nationality question will be asked in Scotland.
Individual electoral registration
6. The importance of research into electoral registers will become even greater over the coming few years. The Political Parties and Elections Bill, currently passing through Parliament, required the Electoral Commission to report on the accuracy and completeness of electoral registers during a transition stage from household electoral registration to individual electoral registration. The Commission’s reports - due to be published annually from 2011 to 2014 - will inform the decision as to whether to permanently move to individual electoral registration or whether to return to a household system.
7. The absence of a nationality question from the Census form in Scotland is likely to mean that the reporting on the progress of individual electoral registration will not be as comprehensive for Scotland as it is for England and Wales.
Mid-term estimates
8. The Commission places great value on the reliability of the population estimates provided by the 2011 Census. The Commission would like to assess the extent of under-registration by comparing the numbers on each register against the mid-term estimates produced by the ONS.
9. Using these figures to produce an approximation of voter registration rates requires there to be sufficient confidence in the robustness of the mid-term estimates, as well as the information that helps to determine eligibility to register.
10. As Karen Dunnell, National Statistician, explained in a written parliamentary question on 6 May 2009:
Care should be taken when interpreting [registration rate] percentages. There may be an underestimation in some areas, as not everyone who is usually resident is entitled to vote. For example foreign citizens from outside of the EU and Commonwealth are not eligible to vote.
Conversely, for other areas the percentages may be over estimates and, in some cases, exceed one hundred per cent as figures for the registered electorate may be inflated. People who have more than one address may register in more than one place (e.g. students may register at parental and term-time addresses) and
61 electoral registration officers vary in how quickly they remove people from the registers after they have moved away from an area or died.
11. Including questions in the Census on nationality - and also second residences - will therefore improve the reliability of the calculated registration rate.
June 2009
62
Memorandum from the Statistics User Forum (OSC 13)
Summary
1. The Statistics User Forum believes that:
a. generally good and timely progress is being made, and that lessons have been learned from problems arising with the 2001 Census that can maximise its reliability; b. the commitment to an address register is welcome, but it is felt that public money will be wasted under current plans which restrict its use just to the Census; reassurance is needed that sufficient resources will be allocated to generating outputs on which largely depends the value to users, particularly relating to appropriate administrative and geographical boundaries; c. the inclusion of a fourth page will allow for more information to be produced which is useful; d. efforts towards harmonisation are welcome, but concerns remain that UK coherence will not be achieved in some areas.
Commentary
2. The Statistics User Forum was established by the Royal Statistical Society in 2005, with financial support from the Economic and Society Research Council. The Forum brings together over 30 statistics user groups and organisations, enabling the development of collective positions on issues affecting what is a diverse user community. Since May 2009 it has been chaired by Andrew Dilnot.
3. The Census represents the single most important source of data for statistics users. This use spans the public, private, voluntary and academic sectors, as well as being of significant interest at the ‘citizen user’ level. The Forum, therefore, welcomes the interest of the Committee in progress on the 2011 Census.
4. Concerns relating to the 2001 Census are well known. Non-response, and actions taken to address it, undermined confidence in the Census and the usefulness of the products. Members of Parliament highlighted some of the problems in the debates on the Statistics and Registration Service Act, a consequence of which has been the PASC responsibility for parliamentary oversight of the official statistical system.
5. The Forum welcomes the careful targeted expenditure on fieldwork to increase response rates, and believes that this will contribute positively to the reliability and usefulness of the data.
63 6. The development costs of the address register for England and Wales, compiled from Post Office, Ordnance Survey and Local Government data, are understood to be £12million. Its use is tightly restricted to the Census and copyright restrictions mean that it will not be maintained thereafter, a substantial waste of public money. The Forum would emphasise that such a register would be of significant benefit to a great many users in all sectors including the ONS itself. This failure of public bodies to operate for the public good in England and Wales is in sharp contrast to Scotland, where a permanent national address register is being created.
7. Additional funding for a fourth page, leading to the inclusion of more questions, enhances the usefulness of the Census. Gathering more information in the same exercise has a benefit to cost-effectiveness. However, the Forum would point out that many users see the absence of a question on income other than in Scotland as a particular missed opportunity to obtain vitally useful information.
8. In 2001 expenditure on outputs represented only three per cent of the Census budget in England and Wales. Users do not feel that this maximised the benefit of Census information. Commitments on the expenditure on all outputs remain to be made, without which the needed resources remain vulnerable to demands arising elsewhere either because of general cutbacks in public expenditure or to finance contingencies.
9. Announcements on statistical disclosure are expected in due course. Users hope that there will be no repeat of the situation in 2001, where late changes undermined much of the prior consultation and led to some census outputs being little used.
10. Securing coherence across the UK is a priority for the Forum. The work of the Registrars General towards greater compatibility of Census information in the four nations is welcome. However, differences in questions, and in methodologies, remain and this will undermine coherence.
11. The Forum’s response has benefited from having among its members organisations with particular interest in the Census, including the Demographics User Group, the Market Research Society, the British Society for Population Studies and the Local Government Association, as well as the input of the wider fellowship of the Royal Statistical Society. These bodies and others will also have made submissions with comments relevant to the needs of statistics users. Many of their points would be supported by the Forum collectively.
June 2009
64 Memorandum from the Local Government Association (OSC 14)
Summary Local authorities make substantial use of census results and have a long history of helping the census offices on operational aspects of the census. This submission sets out a small number of key issues in relation to the user and facilitator roles. Our response relates to census plans for England and Wales (though the Welsh Local Government Association is making a separate response which will include some issues that are specific to Wales). 21 Our key issues from the facilitator perspective are: • That the Office for National Statistics (ONS) should have a realistic expectation of the resources that local government can devote to the census
• That the full range of local government expertise is engaged in the census
• That ONS should clearly communicate what is needed of local authorities, and when it needs to be delivered.
From a user perspective, the key issues are: • That there should be commitment from the ONS to produce outputs for administrative geographies such as wards and parishes
• There should be a full and accurate population count – no census question should put the response rate at risk
• That the address list produced for the census should be available for public good uses.
Introduction 1. We are grateful for the opportunity to comment on progress in planning for the 2011 Census. Local authorities make substantial use of census results. They also help the census offices to carry out the census. Our submission will consider progress from both user and facilitator perspectives. It is informed by discussions with people within local authorities involved with the census as researchers, addressing specialists and as census champions. The local authority side of the Census Advisory Group of the Central-Local Information Partnership (CLIP) has been involved in these discussions, and endorses this submission.
2. The submission identifies areas where we think planning for the census might be improved. It does not dwell on areas where good progress is being made. On the whole, census planning is being taken forward by capable staff in a
21 OSC 05
65 professional way. However, the census represents an investment of nearly £500 million of public money. It would be remiss of us not to point out areas where we feel that this investment may not be optimal.
The facilitator perspective 3. The key issues for local government from the facilitator perspective are:
• That the ONS should have a realistic expectation of the resources that local authorities can devote to the census • That the full range of expertise within local government is engaged in the census process • That the ONS should clearly communicate what is asked of local authorities, and when it needs to be delivered.
4. There is a long history of local authority involvement in helping to carry out the census. For the 2011 census, local authorities are being asked to do more than ever. In principle we welcome this involvement. There were well- documented problems with the 2001 census from a local authority perspective. Closer involvement in planning the 2011 census may help avoid a repeat of these problems.
5. However, census planning has to compete for resources within local authorities against other priorities at a time when public finances are constrained and closely scrutinised. The ONS does not intend to recompense local authorities directly for the resources that they devote to census planning. Most authorities recognise the value of the census to them (for reasons discussed below), and will do their best to ensure a successful outcome. But few council leaders or chief executives would say that the census is amongst their top priorities.
6. Unrealistic expectations on the ONS’ part of what local authorities can do could damage the census project. The ONS should demonstrate flexibility and sensitivity in keeping expectations realistic. Different areas will require different levels of resource to achieve a good outcome. Some areas will be easier to count than others, depending on the nature of the local housing stock and the extent of population turnover. The ONS needs to assess and communicate required involvement in different areas to achieve a consistently good population count across the country. Different councils (or combinations of local public services) may make their contribution to a good outcome in different ways. Some local authorities will require more persuasion
66 than others that the value of the census to them will compensate for the resources put into planning (or that it outweighs other possible use of the same resources).
7. The ONS’ request for each local authority (other than counties – see below) to appoint a Census Liaison Manager (CLM) and Assistant Census Liaison Manager (ACLM) exemplifies an approach that was not sufficiently flexible. Descriptions of roles and responsibilities were produced by the ONS. These are valuable in describing the work required, but several council officers have told us that they are over-prescriptive and unrealistic. The expectation that the CLM should be a chief officer, for example, shows little understanding of the chief officer role. The suggestion that the ACLM be relieved of other duties to concentrate on census work indicates a model that many authorities would find hard to justify. The objection is not to the work required, but to the prescription of the level at which it should be carried out, and how and when it should be carried out.
8. A specific area where local authorities are being asked to do more work than in previous censuses concerns address registers. The ONS has decided to create a single address list. Whatever the merits of that decision, it is too late to plan for an alternative approach. So the task is to make this work. A robust address list should certainly be a cornerstone of an effective census, and should help avoid the errors that occurred in 2001.
9. The plans involve local authority officers (in practice, the local address ‘custodians’) in attempting to resolve discrepancies between the National Land and Property Gazetteer (NLPG), Royal Mail’s Postcode Address File and Ordnance Survey’s Address Layer 2. A series of pilots were carried out in 2008, but the full report of these pilots has not yet been published. It is not yet clear how many addresses will need to be checked, when the checking will be required and how quickly the work has to be done. It is possible that some authorities could be asked to check several thousand addresses.
10. We appreciate that creating a single address list is ground-breaking work. It is evident that the ONS are seeking ways to minimise the amount of checking that has to be done by authorities (not least by introducing a pre-check stage involving the NLPG hub managers, Intelligent Addressing, who are the contractors employed by the Improvement and Development Agency (IDeA) to manage the NLPG on behalf of local government). But the fact remains that
67 without some clarity about the size and timing of the task, it is difficult for local authorities to plan for its completion.
11. The resources to undertake this work are limited. Smaller district councils may have less than one full-time equivalent employee responsible for addressing. What they are required to do for the census has to fit in with regular maintenance of the NLPG and other projects (such as the matching of gazetteer data to electoral registers, which has to be completed before the end of October this year).
12. As well as exemplifying the issue of resourcing, the addressing area shows the importance of clear guidance on what is required and when. Local authorities can and will help in many other elements of the census (identifying hard-to- reach groups and hard-to-count areas, publicizing the census and identifying local accommodation for census staff, to name a few), but will need clear communication of what is wanted.
13. While we are concerned that the ONS does not overestimate the capacity of local authorities to assist in the census project, we are equally concerned that all possible sources of help are used. There are three groups whose assistance seems to be underused at the moment – counties (or regional or sub-regional groups and specialist units), elected members and the research community.
14. The ONS’ requests for practical help are focused on shire districts in those parts of the country that have two-tier local government. This may be appropriate where particular functions are performed at district level (eg addressing), but county employees have local knowledge, expertise and resources that might also be tapped (as do those in specialist units). They may also be able to act in an oversight or co-ordination capacity.
15. There are some 24,000 local councillors in England and Wales. As well as having ultimate responsibility for policy direction and the use of resources within local authorities, they are community representatives. Their engagement in the census project would be beneficial on both counts.
16. The main avenue for interaction between the ONS and the research community is the census sub-group of the Central-Local Information Partnership (CLIP). But this group meets only twice yearly. There is scope for expanding involvement, through more extensive use of CLIP, engagement
68 with other local government research groups, and through wider publicity for the census communities of practice hosted by IDeA.
The user perspective 17. The census is valuable to local authorities because it provides a unique dataset of small area statistics, covering a range of topics in a nationally consistent way. Its uses within councils, and affecting councils, are manifold. They can be summarised as:
• Service planning and delivery • Policy development • Monitoring performance (the census provides denominators for many of the indicators that councils report to central government) • Influencing local government funding • Informing citizens.
18. As well as providing an estimate of the population and its characteristics at a particular point in time, the census provides the benchmark for population statistics for a decade. Errors in the census therefore persist. Local government’s single overriding ambition for the 2011 Census is that it should provide as accurate a population count as possible. It is quite possible that this will be the last conventional census against which alternative data sources can be compared and calibrated. This makes the need for an accurate 2011 Census greater still.
19. The three issues that cause us greatest concern from a user perspective are:
• The ONS has as yet made no commitment to providing census statistics for basic administrative geographies • There should be a full and accurate population count – no census question should not put the response rate at risk • The single address list should be available after the census for public use.
20. Census statistics will be provided for ‘census output areas’ (basically aggregations of postcodes) and aggregations of these. In 2001 output areas nested to local authority wards (and hence districts). However, administrative boundary changes have occurred since then and more are due. Output areas are the only source for councils to use currently to produce new administrative geographies, but they will often not match closely enough. There is no commitment from the ONS as yet that statistics will be available for new
69 administrative areas (be they wards, parishes or districts). This matters to local authorities since the ward (or in some areas parish or community) is the unit of local governance. Moreover, census cross-tabulations which contain large enough numbers to allow analysis at the ward level often contain counts that are too small at the output area level (especially as data are adjusted for confidentiality reasons).
21. This issue can be resolved if census outputs are available for two geographies – ‘statistical’ (ie output area based) and administrative. This possibility depends on the decisions taken on Statistical Disclosure Control (basically, the approach taken to ensure that individuals’ characteristics cannot be determined from aggregated statistics). In 2001 the application of Statistical Disclosure Control rendered unworkable some output area statistics (specifically in origin/destination matrices). The decisions on Statistical Disclosure Control need to give full weight to user needs for more than one output geography.
22. We appreciate that the census questions are largely outside the Committee’s remit. We would like to register our wish that none of the questions should adversely affect response to the census, with consequences for its completeness. There are new questions on citizenship, national identity and intention regarding length of stay in the UK which might have an adverse effect. We recommend that the Committee seek assurance that all questions have been adequately tested for their possible effect on response. The last real opportunity to test these questions will be the Census rehearsal in October 2009.
23. The creation of the single address list for the census has been priced by the ONS at £12 million. This does not include the input from local authority custodians in checking addresses. However it is costed, it is clear that the address list represents a significant investment of public money.
24. However, because of issues around intellectual property rights, the use of the address list for the public good is constrained. Our understanding is that there is no intention that the census address list should be adopted as the basis for developing a single national address register, despite the value that such a register would represent for the planning and delivery of public services. A single address register should be an integral part of the ONS’ ‘Beyond 2011’ agenda. In the nearer term, and specifically in relation to the census, local authorities will not be provided with those addresses that do not appear on the
70 NLPG. They will not, therefore, be able to view the final address list used in carrying out the census. This will make it difficult for authorities to form a view, or offer their local expertise, concerning the completeness of coverage of the census.
25. We do not intend to recapitulate the arguments around intellectual property rights and addressing. It would be appropriate for the Committee to ask why the public good uses of the address list outlined in the previous paragraph will not be possible.
June 2009
71 Memorandum from Luton Borough Council (OSC 15)
Executive Summary
Luton Borough Council (LBC) welcomes the opportunity to contribute to the Public Administration Select Committee’s investigation regarding progress on the Census and has concerns over several issues.
i) LBC recognises the importance of the Census in providing baseline data for resource allocation and service planning.
ii) LBC is concerned whether the ONS has adequate resources to support its plans to increase enumeration in places such as Luton, that have a prevalence of hard to reach groups and the low response rate in Luton in the 2001 census. LBC would also like the ONS to effectively engage with local authorities to make use of the local knowledge to improve response rates.
iii) With high profile data losses and public concerns about the use of government data, LBC would like assurances that the ONS and Government more widely are putting plans and processes in place to prevent future data losses adversely affecting the Census.
iv) LBC recognises the importance of ONS having an accurate address base upon which to undertake the Census but has reservations about the processes that ONS are proposing to adopt and related contractual issues .
Luton Borough Council Response:
1. Luton Borough Council welcomes the opportunity to provide the Public Administration Select Committee with comments on how the ONS are progressing the 2011 Census.
2. Given the importance of the Census in providing a baseline for resource allocation at the national and local level and the concerns about the quality of the 2001 Census (and subsequent mid year estimates) Luton Borough Council (LBC) supports the ONS objective of improving data quality in 2011 but has reservations as to the whether the ONS has the capacity to deliver and hence whether the approach will be successful.
3. LBC see the success of the Census being related to the following points that are explored further below:
a) Effective local liaison before and during the Census enumeration processes; and
72
b) Real and perceived data security,
4. LBC supports the plans of the ONS to engage with local authorities and local strategic partnerships in order to facilitate access to hard to enumerate groups.
5. LBC would like PASC to pursue with the ONS whether the ONS has the resources to enter into successful liaison processes with all local authorities and LSP in England and Wales as outlined in its plans for the Census.
6. In the preparation for the 2001 Census the ONS announced plans to work closely with local authorities to improve enumeration rates. LBC identified officers to lead on this and facilitate work with the community but this close working did not occur. Can the ONS provide a real commitment that their proposed approach will work this time especially given resource and time constraints at both the ONS and within local authorities?
7. LBC are concerned that the ONS do not underestimate the potential language and access barriers to completing census forms and work with local authorities to maximise intelligence at local level on hard to reach groups. In light of the ONS plans to reduce the percentage of staff allocated to the East of England from 10 per cent of the UK total resources in 2001 to 8 per cent in 2011 (London’s share will rise form 16 per cent to 24 per cent), the ONS needs to recognise that Luton has hard to reach groups. A lower resource allocation could have implications for the response rate in Luton. In the 2001 Census, Luton had a response rate of 86 per cent (19th lowest). The ONS need to recognise that Luton has hard to find areas and need to explain how they are allocating resources throughout the regions. LBC wish PASC to explore with the ONS how they will be allocating resources to support the enumeration of hard to reach groups in areas such as Luton
8. The security of personal information or perceived lack of it has taken a high public profile in recent years with a number of electronic datasets being lost. Any major loss of personal data by any public sector organisation, especially in the run-up to the Census, have a major impact upon response rates as the public’s confidence in government to securely handle their data is undermined. In light of this, PASC are asked to consider how the Government and the wider public sector can show a stronger commitment to data security and how losses of personal information will be prevented.
9. There are concerns that data supplied to the public sector is being joined up particularly in the context of preventing terrorism and violent extremism. The risk to the Census is that the public, particularly those within those communities under the spotlight of the security and intelligence services, will see the Census as another trawl for data that will be used to investigate and observe them. This could undermine the Census is areas such as Luton that have high populations within
73 ethnic groups. PASC should be challenging the ONS and the Government to publicly demonstrate how the restrictions on the use of Census data as outlined in the Census Act 1920, the Statistical and Registration Services Act 2007 and the White Paper will be guaranteed particularly given the exemption under the 2007 Act in relation to “national security”.
10. LBC recognises the value of the Census data to public and private sector organisations. LBC is acutely aware that current information is most useful and would want to see minimal delay between data collection and publication. LBC would like PASC to challenge the ONS’ plans to ensure that local data is available in a timely manner after collection to avoid its usefulness being questioned.
11. The ONS have outlined a programme of work with local authorities to ensure that the Census is successful. This work includes address matching, liaison with partners and the community, providing staff and accommodation to support the Census processes. LBC is supportive of this work programme as it can see the benefits of having accurate baseline information. However PASC will be aware of the constraints imposed by tight local government financial settlements and LBC wishes to remind PASC that the work programme the ONS have identified that requires significant local authority input has to be achieved by local authorities without any additional resources. Given the opportunity costs to local authorities of supporting the Census it is imperative that local authorities have total confidence in the resultant data. 12. The ONS is merging several major UK address databases to ensure all residential properties receive a census form. LBC is concerned it will have to do unnecessary work as there is no indication of how data anomalies will be resolved. PASC are therefore requested to seek clarification from the ONS as to how it will resolve data anomalies and to encourage the ONS to work with LLPG Custodians to develop effective and efficient processes to achieve a comprehensive address database. 13. LBC is concerned that ONS proposed address matching processes could "gift" local authority owned address data to our competitors during the anomaly resolution process. This is contrary to the contracts local authorities have sign-up to regarding the management of their address data. 14. LBC is concerned about the amount of work required if the ONS increases the survey granularity. At the moment we store postal addresses within the land and property gazetteer but the ONS is proposing to identify all households, not just housing in multiple occupation. This will have resource implications for local authorities. 15. LBC is concerned that its address systems, which fulfil its statutory responsibilities and adhere to the national Mapping Services Agreement and BS 7666, will be unable to support the level of detail required by the ONS.
74 16. LBC will increase its chances of identifying "hidden" households if addresses in all the council’s databases are matched to the main gazetteer. This will take a huge amount of work but will bring efficiency and service improvement opportunities in addition to increasing census coverage. It will also lay the foundation to start our residents’ database. We already have a rolling programme of work to match addresses but it would be good to use the census as leverage to persuade some of the remaining services to start cleansing their databases. Any additional resources that could be made available to help with this would be good (both in terms of purchasing suitable software and temporary staff) and contribute to the wider efficiency programme of local authorities.
June 2009
75 Memorandum from Wandsworth Council (OSC 16)
Summary
• Local authorities need to have fuller involvement in address register development to ensure accuracy and complete coverage. • Areas with highly mobile populations, a large proportion of young single males and high numbers of flats/apartments should be included in the definition of hard-to-count. • Proposals for standard output geographies need to be reviewed with regard to disclosure, comparability over time and usefulness. • The ONS needs to facilitate local authorities to amalgamate data to local areas without compounding errors from disclosure control. • Effective communication is integral to a successful Census and publicity needs to be far reaching, with a clear, simple message. • Systems need to be in place to ensure maximum gain from enumerator follow-up.
Introduction
1.1 Wandsworth Council welcomes the White Paper published in December 2008 which set out proposals for the 2011 Census and in particular, areas for partnership working and local authority liaison. This approach is considered to be essential for achieving full coverage, particularly in areas which are difficult to enumerate.
1.2 However, for local authorities to invest significant resources in this process, they need to be confident that the outputs of the Census will be fit for purpose and provide policy decision makers with an accurate, timely and complete dataset.
1.3 The results of the 2011 Census will impact on local authority funding and service delivery planning for a further ten years, providing a benchmark for population estimates and calculation of statistical indices, and providing a unique source of information on a range of characteristics of the local population. It is therefore imperative that quality information is delivered, particularly in the current economic climate.
1.4 The Council considers that there are still several areas of concern in respect of 2011 Census preparation that pose significant risk to a successful outcome and these are detailed below.
76 Coverage & Address Register
2.1 Central to complete coverage is the development of a full and accurate address register to ensure all households are surveyed. Under the current proposals, local authorities will have the opportunity to verify/cleanse a small percentage of addresses within their authority area (approximately 1%) which have not been successfully resolved by the ONS’s own address matching processes. This involvement is designed to reassure local authorities that their population count is correct as they will have been involved in preparation of the survey address list.
2.2 This proposal does not involve local authorities sufficiently to instil confidence that full coverage will be achieved. Local authorities will not have had sight of 99% of addresses within their boundary and will remain unaware of how the ONS have resolved other conflicts between Local Land and Property Gazetteers and commercial address products. Local authorities should have access to the full address lists to be used on Census day in order to have confidence in them and utilise their local knowledge more effectively to help ensure the accuracy of the Census address list.
Identifying Hard-to-Count Areas
3.1 The ONS needs to adapt a flexible approach to identifying hard-to-count areas, not just focussing on areas where deprivation or language may act as a barrier to participation.
3.2 A one size fits all approach is not considered appropriate to achieve full coverage as some areas have a high degree of stability whilst other have a very mobile population and large migration flows. The ONS should recognise that new migrants (internal and external to the UK) to an area are more difficult to reach than established residents.
3.3 Following the recognised undercount in 2001, the definition of hard-to-count areas needs to include areas with a high proportion of young, single men (aged 18-35). The hours worked by field staff in these areas would need to mirror the days/hours most likely to find young men at home. Field work should also include allowance for other means of contacting these groups, in addition to home based contact e.g. local bars and gyms.
3.4 Hard-to-count areas should also include those with high numbers of flats/apartments as the number of such properties recorded as vacant in the 2001 Census exceeded those identified in local administrative records, particularly in social housing blocks. This suggests that enumerators failing to get a response chose to code properties as vacant rather than continue to try to get a response. The Census enumerator payment system should be structured
77 to reward enumerators achieving high percentage return levels, particularly in hard-to-count areas.
Disclosure & Output Geographies
4.1 Whilst the stability of the OA-SOA hierarchy is welcomed, it is also essential for local authorities to have access to ward level data. As many data sets were not published at SOA level in 2001, there is limited reliable comparable data for time-series analysis should ward level data not be published in 2011. Local authorities will need to commission vast amounts of data at extra cost if these issues are not addressed, affecting the timeliness and usefulness of the outputs.
4.2 Depending on disclosure control decisions to be taken for 2011, the detail of data available as standard outputs at SOA level may be significantly reduced compared with 2001 ward outputs as these smaller geographies may pose a greater disclosure risk. Even where data is available at SOA level, local authorities still require the same output at ward level, as amalgamating a number of areas incorporating data disclosure control features can lead to inaccuracies for the combined areas.
4.3 Outputs need to be flexible and only rounded once at the point of publication. The ONS needs to facilitate local authorities to amalgamate data to local areas without compounding errors from disclosure control. Local authorities, researchers, academics etc should have greater access to raw data products (via licence) than the public. This is particularly important for datasets with a fine grain of detail which disclosure control/rounding can destroy such as workplace travel datasets. The data needs to be fit for purpose.
Communication
5.1 The 2008 White Paper provided very little detail on the proposed strategy for publicising and increasing awareness of the Census. Effective communication is integral to a successful Census and publicity needs to be far reaching. Residents need to understand why their return is important, how it will benefit them and their local area and also how the information will be used.
5.2 There is generally increasing apathy towards surveys, concern over confidentiality and fear of ‘linked systems’ for those who do not want to be identified. A clear and simple message needs to be relayed that reassures people and encourages them to return the form.
5.3 The helpline needs to have sufficient capacity to deal with demand.
78
Processes
6.1 It is understood that due to bar-coding of questionnaires the ONS do not consider it feasible for enumerators to carry spare forms. This procedure needs to be reviewed urgently and a system devised whereby enumerators can distribute questionnaires to people they make contact with, particularly in relation to the comments on contacting hard-to-count groups away from the home. Enumerators will be very lucky to make contact with a hard-to-count household twice and the initial opportunity to encourage participation will have been lost.
June 2009
79 Memorandum from Eileen Howes and John Hollis, Greater London Authority (OSC 17)
Our main concerns are:
• That coverage of the population in London is improved considerably from that in 2001.
• The statistical disclosure control policy must ensure that tables are consistent and additive.
• That as yet there is no commitment from the ONS to produce outputs for administrative geographies such as wards and parishes.
• That the address list produced for the census should be available for public good uses.
• That a better way is negotiated to allow use of appropriate and accurate data for public sector users through licensed access arrangements, for example allowing them to use unrounded migration and travel to work data. The 2001 method of rounding destroyed a number of datasets which are designed to contain small numbers, in particular the OA level special workplace and migration statistics.
• That during the follow-up work in the field enumerators (or collectors) should be in a position to give new forms to people who have mislaid them or who need another form.
• That there are as yet no plans to incorporate any serious checking of forms into the process of posting back and scanning of forms. This should be a fundamental part of the quality assurance process and demands urgent consideration by the ONS.
1. Coverage
Some of the extra questions included will help get a better understanding of the population but there is still concern that questions such as those on intention to stay, nationality and national identity may not provide reliable and usable statistics and may contribute to lower overall response. We feel that the ONS is making laudable efforts to improve the coverage and improve the population counts but this may be at the expense of paying insufficient attention to the more general questions on the form. There appears to be no intention to check returned forms for completeness or to follow up missing questions or incomplete returns.
80 2. Statistical Disclosure Control (SDC)
The disclosure control policy must produce tables which are additive. We would like to see statistics from nested geographies to add up to the total for the geography. Tables must be consistent, we do not want to spend years trying to explain why we can get a different figure for any statistic from looking at another table. Double geography datasets for the smallest area levels were destroyed by the rounding applied to them in 2001. We would like them to be fit for purpose after any disclosure control methods are applied to them. The policy needs to allow two geographies – statistical and administrative - and to allow local government and other users to get access to the data they need for administrative areas down to wards, parishes and communities.
3. Geography
Census geography depends upon SDC policy. Local government users need administrative geography as well as statistical. It is untenable that at this late stage of planning there is still no commitment from the ONS to produce accurate data for administrative areas. These include local authority districts, electoral wards, parishes and communities. Councils have statutory duties based on these areas and local government has built a business case for the questions in the census and the data derived from them. Local government has cooperated at many levels with the ONS and supported it as much as possible. The ONS is asking local authorities to provide substantial resources over the next few years supporting the 2011 Census and in return should endeavour to provide the data that local authorities have indicated are required.
The ONS geography consultation questionnaire did not ask users to specify their preferred geography for the census output. It asked a range of questions such as ‘if we produced x would you use it?’ to which users would normally answer ‘yes’ because we try to make the most of all available data. The ONS did not ask what our preferred geography was or what we actually wanted or needed. The ONS is aware that users feel that the questionnaire was designed to produce the answers that the ONS wanted. The consultation was flawed as a result.
4. Address lists
There is widespread concern that the amount of time and effort spent in reconciling address lists, while essential for improving coverage in the 2011 Census, seems unlikely to be used to improve all the address lists involved as things stand. It seems that all that effort and public money spent will only be used once while it could be used for more than this.
5. Licensing
81 There may be a need to provide data to trusted users with a specific need via special licence arrangements. The current special licence arrangements, while a big step forward, are too bureaucratic and onerous on both sides to work smoothly when the census data are published. Local authorities need to be sure that they can get the data they need for the geography they need. They should be treated as serious and trusted users of data with a recognised need for data that is fit for purpose. This may necessitate specific licence arrangements to ensure access to certain data. London’s need for detailed population data may well be unique, due to the special characteristics of its population. The GLA will need detailed cross-tabulations of sensitive characteristics such as ethnic group, country of birth and religion.
6. Fieldwork
Current plans are that forms must be distributed from a central point and experience in the field indicates that follow-up staff will have the best chance of success by being in a position to give a new form to a household who asks for one.
We are also concerned that plans so far do not appear to incorporate any checking of forms when they are returned. Checking forms for completeness has always been a fundamental part of the census fieldwork and is important in improving all the census data.
June 2009
82
Memorandum from Westminster City Council (OSC 18)
2011 Census Preparations
I am writing to inform the Committee of some of the concerns Westminster City Council has about the 2011 Census in a hope that it will help inform the Committee’s review.
As you may be aware Westminster successfully challenged the 2001 Census for the City which lead to a significant national population amendment and an amending report issued by the then Office for the Deputy Prime Minister (ODPM) regarding local government finance settlement.
Westminster’s challenge also lead to the former Statistics Commission making recommendations concerning the preparations for the 2011 Census.
Although the City Council recognises that much work has been enacted in an attempt to rectify the methodological shortcomings of the 2001 Census we still have significant concerns that the 2011 Census will prove an inaccurate count of our population.
We believe that there is a significant risk to the credibility of the 2011 Census because not enough has been done in the interceding years to improve the measurement of migration. Urgent recommendations following the reports into Westminster’s 2001 undercount included the need to set up a national address register which has not come to fruition. Instead migration measurement has evolved in a piecemeal fashion relying on poorly performing surveys and statistical modelling.
As a result we have no confidence that the population estimates of the past few years will be reflected in the 2011 Census and this will inevitably lead to the same reputation problems as the 2001 Census suffered.
Our lack of confidence may be shared by a sizable number of councils as evidenced by a survey we conducted in January.
I apologise that this information has not reached you before your stipulated deadline of 11th June 2009. I am happy to supply any further information or clarification to the committee and if appropriate to provide oral evidence to the committee.
June 2009
83 Memorandum from Dame Karen Dunnell DCB, National Statistician
During the recent Public Administration Select Committee hearing on preparations for the 2011 Census, I and my colleagues promised to provide additional detailed information requested by the Committee. I would also like to take this opportunity to provide additional clarification of a small number of points.
1. Mr Prentice asked how we identify who, within the household, would have legal responsibility for ensuring that a questionnaire was completed. This is defined on the front of the Census questionnaire. For the Census rehearsal this states that:
‘The householder/joint householder should complete this questionnaire. A householder is a person who: owns/rents (or jointly owns/rents) accommodation; and/or is responsible (or jointly responsible) for paying household bills and expenses.’
2. You asked how much we are going to save by sending the questionnaire out as opposed to delivering it. We can confirm that the figure quoted by Mr Watson during the hearing, an estimated £20m, is correct.
3. In discussing the address register for the Census, I stated that the address suppliers will each have the address register we create for the Census. To clarify this, the additional addresses that ONS finds during the pre Census address check in the field will indeed be shared with Royal Mail, Ordnance Survey and Local Government Information House, but under the terms of the data sharing agreement signed between all parties, ONS will not be able to share addresses found on one of the address sources that were not held on another source. This limitation is necessary because of the intellectual property rights of the individual suppliers. ONS will not share any addresses identified during the main Census operation for example from calls to the contact centre. These addresses are regarded as Census information and are covered by the Census confidentiality commitments.
4. During the discussion on community groups, Mr Watson offered to provide a list of the different community groups that the Census team have been liaising with. This list is provided as Annex A.
5. Mr Flynn asked about the resilience of the internet collection system. I can reassure the Committee that we have good plans in place to manage the peak of internet activity. The peak will be on Census day itself, but we expect the majority of people who complete using the online facility to do so either before or after Census day. This will be perfectly acceptable with the online system available over a 2 month period. During the peak period we will operate what was described in the hearing as ‘a graceful deferral’ policy. This simply means that if the system is close to reaching its full capacity, new respondents will receive a message saying
84 the system is busy and inviting them to try again later. In this way the resilience of the system will be ensured. More details are included in Annex B.
I would be happy to provide any additional details or clarification.
Annex A
Engagement with the following groups is ongoing, with good progress made so far.
Age Concern Big Issue Black Londoners Forum Board of Deputies of British Jews British Deaf Association British Sikh Federation British Ravidassian Chinese in Britain Carers UK Communities First (Wales) Citizens Advice Bureau Federation of Irish Societies Equality and Human Rights Commission Ghanaian Community Group Friends Family & Travellers Help the Aged/ Help the Aged Wales Gypsy and Traveller Exchange (Leeds) Interfaith Network for the UK Hindu Forum for Britain Ligali Organisation Jewish Haredi community Mind/Mind Cymru Liberty National Association of British Arabs Muslim Council of Britain/Wales National Centre for Languages CiLT (engagement currently suspended in line with government direction) National Association of Councils of National Literacy Trust Voluntary Organisations National Federation of the Blind ROTA Refugee Council Roma RNIB SCOPE RNID Stonewall Shelter Welsh Language Board The Runnymede Trust Race Equality Unit
Annex B
This note provides a more detailed response on Census internet capacity than was given during the PASC hearing itself.
Census day is 27 March 2011, and this is the reference day for determining whether someone should be counted in the Census. However, in practice, responses can be made as soon as a questionnaire is received by a household; throughout the period when Census staff are actively following up non-responders; and beyond. It is not a
85 legal requirement to complete the Census questionnaire on Census day. Based on experience from the 2001 Census, we expect a few million questionnaires will be returned before Census day; the vast bulk will be returned within 10 days of Census day; and there will be a long tail of questionnaires returned thereafter.
The paper questionnaire contains an internet access code, which acts as a unique password to access the internet data capture system Therefore the earliest time that someone can complete the Census online is when they receive their paper questionnaire. Questionnaires will be delivered up to three weeks before the 27 March 2011 Census day. Census questionnaires can be completed on line between Friday 4 March 2011 and Friday 6 May 2011.
Australia, New Zealand, and Canada carry out five yearly Censuses and each offered a Census internet data capture option for the first time for their 2006 Censuses. ONS has learnt from these experiences in designing its internet data capture system, and in understanding the likely patterns of response rates. Canada had a similar Census design to that proposed for England and Wales in 2011, and achieved the highest internet response rate in 2006 of about 18%, with a peak of about 7,000 concurrent users. This international experience has helped to predict the number of responses we might expect day by day and how this might vary by day of the week and by time of day. ONS is also learning from the Scotland 2009 Rehearsal. Based on all of this experience, ONS expects use of the internet data capture system to start almost immediately it is made available, to be spread out across the entire period the application is available, but with a particular peak on Census Day itself. Also based on international Census experience, and other work, ONS is currently planning for 25% online responses, which amounts to about 6.5m households for England and Wales.
The peak load for the Census application is likely to occur on Census Day, and to tail off quickly on subsequent days. It is expensive to build capacity to handle the extreme peak for just a few hours on Census Day. Through a process of very close monitoring, it is possible to determine whether the internet system is close to reaching its fill capacity. If that does happen, then those who have already logged on to the system will all be able to continue to complete their Census questionnaires without interruption. However anyone else trying to log on during an unusually busy period will receive a message telling them that the online application is busy at the moment and asking them to try again later. ONS expects that this might only be an issue for a short period on Census Day itself. Experience from Canada in 2006 was that this ‘graceful deferral’ did not create a problem, and was acceptable to Census respondents.
July 2009
86