The Office for Students is over a year old now, and today gain its full regulatory powers. Even during their initial year, they have made significant interventions in higher education on widening participation, safeguarding students and contextual offers, as well as focusing on getting providers onto the register. However today marks a particularly significant step for higher education, as the OfS gets its teeth and fully transforms into a regulator, focused on holding universities to account and ensuring they are providing for the student body. Undoubtably these interventions will increase as they get into their stride over the next year, particularly as they will now operate under the Minister who was responsible for their transformation from the Higher Education Funding Council for England (HEFCE), Jo Johnson.
We are using today’s changes as an opportunity to look at one area where policy still needs to settle down. The operation of collection of data in higher education is often thought of as necessary but of less interest than other work. However, the data that are collected on higher education reflect our ability to understand the space in which we work and dictate the ability to produce evidence-based policy. All of us who work in HE policy are reliant on these data to some degree.
In November last year, the Office for Students published their data strategy which set out their approach to data between 2018 and 2021. The principles this set out were:
- Ethical behaviours and compliance
- Transparency
- Robust and innovative analysis
- Reducing burden and working with others
- Quality
Their interventions to date have largely kept to these important principles – although a recent Buzzfeed article suggests they might need to take action over universities’ transparency on the data they collect. However on the principle of reducing burdens and working with others, I would highlight two particular areas where they are coming up short.
- Removing the requirement to collect non-academic staff and estates data
In their data strategy, the OfS stated they would no longer require the collection of data on either university estates or non-academic staff. The justification for this was a review of how the OfS’s requirements differed from HEFCE and that this would lead to a burden reduction.
While reducing the number of data collections would seem to lead to a reduction in burden, it is a more complex issue than this. It is unlikely that the demand for things such as the carbon emissions of universities or the diversity and equality characteristics of non-academic staff will go away. If the removal of these datasets is replaced by universities having to respond to endless Freedom of Information requests, the burden will not be reduced.
This change also impacts in terms of ‘working with others’. The Office for Students no longer requiring the data to be collected doesn’t alter the requirements for these data to be collected in Scotland, Wales and Northern Ireland. This change will mean the end to a consistent collection of data across the UK, and inevitably cost rises for the devolved administrations, where costs will be shared between around 30 universities rather than around 160.
2. Seeking to take over the collection of universities’ finance data
At the beginning of last month, the Office for Students released a consultation on the future of ‘Financial and student number data collection’. As part of regulation, universities have to report on their financial position and student number information, through both forecasts and audited actual financial information. The actual finance information has always been collected by the Higher Education Statistics Agency, with universities previously submitting forecasts to HEFCE in England.
The consultation proposes the collection of data is taken over in its entirety by the OfS. The reasoning given behind this is that the data collected are ‘commercially sensitive’. This seems like a strange move, given the changes that the Higher Education Research Act (2017) brought about include making HESA the Designated Data Body. HESA has historically collected some of the most sensitive data in higher education on things such as the gender, ethnicity and sexual orientation of students, as well as detailed financial information. Therefore it is difficult to understand this justification. For universities, this change would mean increasing the number of places they have to return data to, which in turn increases the burden. It seems to move away from the common data management principle of ‘collect data once, use many times’.
The combination of these changes suggests that there is more work to be done on how to reduce the burden in the collection of data from universities. It is a more complex issue than simply stopping collecting data in some areas. It will only increase in importance as the Office for Students moves into full operation, and the outcomes from the review of the Teaching Excellence Framework become clear, as well as the OfS looking to review and expand the National Student Survey. If we do not stick to the principle of reducing the burden of data collection, universities may be left with an ever increasing burden of data collection without additional resources to manage it.