In these increasingly data-driven times organisations are take more strategic approaches to the use and governance of data. Every organisation should have a data strategy as a part of its broader strategic planning framework, alongside expected strategies for financial, HR, estates and others.
The positioning of data at the heart of the new OfS regulatory framework indicates how far it has travelled from the days when data issues existed only at the margins of the broader policy debate. The publication of the OfS data strategy is a milestone in this transformation – and sets out a vision for the role of data in regulation over the next three years as well as defining some of the mood around this issue for the future.
HE data in the post-92 world
I have written previously about the broader history of data in HE. The role of data in funding and regulation over the past 25 years was defined very simply in the 1992 legislation that established the HE funding councils across the UK. That legislation gave some very broad powers to the funding councils to demand whatever data they needed from providers, but was silent on anything about how that would work in practice.
The priority in the early 1990s was the creation of a single UK-wide data infrastructure that encompassed all the elements of the pre-1992 binary sector. In many ways the agreement to establish HESA as a UK-wide body went against the tide of the devolution of HE policy, funding, and regulation across the four administrations.
The following two decades saw the evolution of a sector-wide data system built largely on evolving custom and practice and punctuated by ad hoc agreements that addressed specific issues and problems as they arose. The funding councils’ data collection powers were operationalised by HESA as their agents; the submission of data to HESA, along with the obligation to subscribe to HESA, was a condition of funding. The data collections became more sophisticated and the quality expectations of the data increased steadily over time.
The system worked; some compromises were occasionally made and some messy issues necessitated some awkward solutions. But the funding councils successfully delivered systems to support policy, funding, and regulation and in doing so developed an enviable analytical capability.
Data in the OfS world
The 2017 HE and Research Act (HERA) provided an opportunity to codify the role and responsibilities around data and wrote into statute the concept of the Designated Data Body (DDB) to provide data collection services and expertise to the English HE sector and its regulator. HESA was, unsurprisingly, appointed to that role. The OfS consulted on and published a data-driven regulatory framework and the majority of the 60-plus data analysts that worked for HEFCE and OFFA transferred into the new regulator.
Data is a big deal for OfS and the publication of the data strategy sets out the principles and approach to data in a way that should improve the debate and understanding of data at a sector level. This has to be a good thing, especially given the extent to which the sector has sometimes felt brutalised by the perceived weaponisation of data, and to which the burden of data collection has become a long-running complaint.
The strategy clearly needs to tell a good story on the issue of burden, and the frequent reference to this in the text suggests that it has been at the forefront of thinking. The section on reducing burden trumpets four wins in this space already – though scratching beneath the surface of these does raise some questions.
It is true that OfS is not running the alternative provider early statistics return any more (the dreadfully acronymned HEAPES) but the institutions formerly known as alternative providers are expected to do the early-year HESES return instead. This looks like a slightly disingenuous win.
The announcements that the HESA staff return would no longer include non-academic staff and that the HESA estates data is no longer compulsory is odd given that both of these were previously justified by HEFCE on the basis on general legislation around equalities and carbon monitoring respectively. It is not clear if the world has moved on from these issues, or whether we are seeing OfS taking a less robust line than HEFCE here.
The strategy makes numerous references to the importance of the Data Landscape Steering Group and the two codes of practice covering the demand and supply of HE data. But it is unfortunate that the assessment of burden which is central to the demand-side code has not been undertaken by OfS for the current requirements because it ran out of time. I wonder if this more relaxed attitude to quality and completeness will be reflected back to providers when they are struggling to make their data returns next year?
The strategy sets out a usefully broad definition of data and describes a model where OfS acquires and analyses data from a very broad range of sources including the usual suspects (HESA, UCAS, SLC, LEO), the slightly less-usual suspects (OIA and QAA) and the new kids on the block (social media, web analytics and big data). There is a clearly articulated vision for data in the world of OfS and a comprehensive breakdown of how data will be used to support the various activities that make up the regulatory framework.
The section on data quality carries forward much of the thinking from HEFCE days and reiterates the fact that the responsibility for data quality rests ultimately with the provider’s governing body. With so much of the regulatory framework now dependant on data, the OfS will take an ever-more critical view of data quality issues and providers that don’t recognise and respond to this are likely to face uncomfortable conversations with their regulator.
The section on reducing burden and working with others sets out some useful principles and approaches for managing burden and working cooperatively. It casts a leading role for OfS in the broader oversight of the English data landscape which goes significantly beyond the post-92 world of HE data. This appears to include an assertion that any HESA data sharing agreement will in future require the approval of OfS.
OfS are setting out a distinctly different approach to data than the one taken by its predecessor. One of its first acts earlier this year was to sign-up to the national statistics code of practice and adhere to stricter rules around transparency and access to data. This was something that HEFCE successfully avoided for many years and OfS must be applauded for taking this step from the outset.
The last word?
The data strategy is linked to the broader OfS strategy which runs from 2018-21; the data strategy is explicitly pitched as being a “strategy in development” with the promise of a longer-term data strategy being developed for 2021 and beyond.
Organisations that have a data strategy often find that the process of creating the strategy is valuable since it flushes out the different perceptions and (mis)understandings around data issues and then builds a shared vision of the future. The OfS data strategy is slightly different to others since it directly impacts and drives data activities not just within OfS but across the entire sector.
This interim data strategy has been developed without significant engagement with the sector and I hope that we will now see a much broader and richer conversation about how OfS collects and uses data. This document makes a good starting point for that conversation and sets out some clearly defined and ambitious aspirations that now need to turn into reality. I don’t think the debate around HE data will quietly recede anytime soon.