The journey to create a more effective and less-burdensome HE data landscape has been underway for a number of years now – ever since the Regulatory Partnership Group (RPG) commissioned the first studies in this area following the 2011 White Paper ‘Students at the Heart of the System’.
Those early RPG studies identified a lack of oversight and leadership as the cause of many inconsistent and duplicative behaviours of the various data collectors. While much of the work undertaken since then has focused on issues like the standardisation and rationalisation of data flows, the fundamental need has been for a change in behaviours.
The Data Landscape Steering Group has been established to provide an overview and leadership of ideas across the data landscape, and to encourage a change in behaviour in HE data collections. The group has developed and consulted on a set of behaviours, enshrined in codes of practice, that should address those issues of duplication and a lack of coherence in data collections.
There are two codes of practice – one for the demand-side (the data collectors) and one for the supply-side (the HE providers that are supplying data). The supply-side code of practice is based on one that was developed by the HE funding councils across the UK for the data collections that they run, either directly or through HESA. It is based on three principles: honesty, impartiality and rigour, and has been expanded to apply to all data returns that HE providers make.
The supply-side code of practice states that the data submitted by HE providers should genuinely reflect the characteristics and events being reported on, and that the providers should act in a transparent manner and not withhold information. The preparation of data should be impartial, objective and should be done in accordance with repeatable, documented processes.
The demand-side code of practice reflects those principles of honesty, impartiality and rigour back to the data collectors and sets out expected behaviours in the management and governance of data collections.
Data collectors should be honest and open about the intended uses for data and should respond to scrutiny of collection requests. Data requests should be defined objectively and aim to offer the best evidence for the stated use. Data definitions should align with relevant published standards and any duplication of an existing data collection must be supported by a strong rationale. Data collectors should be able to justify requests from an informed position concerning the impact on data suppliers.
The demand-side code of practice requires the assessment of burden, and a methodology has been developed to support this. The methodology provides a framework for assessing the impact of data requests and aims to create a better shared understanding of the issues that contribute to the overall burden.
What does it all mean?
With so many independent and autonomous organisations collecting data, the Data Landscape Steering Group does not have (and does not seek) the sort of hard authority that could mandate a change in behaviours. What we do have, through the development and publication of these codes of practice, is an opportunity for organisations on both the demand and supply sides of data collection to create a new compact that will improve the management and governance of data assets as they flow across the sector. For HE providers, this means ensuring that the high standards applied to HESA and funding council returns are extended to all external data returns. For data collectors, this means reviewing processes against the code of practice and taking actions to address deficiencies. Engagement in a comprehensive and mature conversation about burden is a responsibility that falls on us all.
The building blocks of a new data landscape are starting to fall into place; more technical developments like the HECoS subject coding system and the HESA Data Futures project need to be aligned with a change in behaviours around the governance and management of HE data flows. The increasing focus on data-driven funding and regulation makes this work more important than ever.