Consultation
Consultation on the Approved
Researcher Scheme
February 2015
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ONS Approved Researcher Consultation
1. Background
 The Office for National Statistics (ONS) is the UK’s largest independent producer of official
statistics and is the recognised National Statistical Institute (NSI) for the UK.
 ONS openly publishes an extensive range of statistics based on the Census, surveys and
registration data, but some data cannot be published, because of the risk of disclosure, even
though these data are valuable for research purposes. Rather than disseminating these data
openly, ONS has the ability to manage access to Approved Researchers for statistical research
purposes. This consultation looks at the criteria, processes and safeguards in relation to
making these data available.
 One of ONS's key aims is to ensure the broadest possible use of the public data it holds. Where
the resultant research is of benefit to the social and economic well-being of the population, it
allows safe and secure access to the underlying microdata used to produce published statistics
for further analysis.
 The Statistics and Registration Service Act 20071 (SRSA) states that ONS may give access to
its microdata to people who have lawful permission to use it and that such permission may be
given to those that ONS designates as Approved Researchers.
 The criteria and process used to designate Approved Researchers were set, by the National
Statistician, in 2008. Although these have worked well since that time, a number of limitations
have been identified by ONS, its users and other bodies who disseminate access to microdata
(e.g. The UK Data Service [UKDS] and Health and Social Care Information Centre [HSCIC]).
 ONS is currently reviewing whether improvements can be made, to help ensure best use of its
data whilst protecting the confidentiality of respondents.
 Other organisations which provide access to similar data, such as the UKDS and HSCIC, may
harmonise their practices to reflect the eventual changes applied to ONS data, to ensure
consistency of approach, and efficiency in practice.
 ONS has appointed an Expert Steering Group, composed of ONS staff and external
stakeholders, to conduct this review and to submit a set of recommendations to the National
Statistician upon its completion.
 To inform this review, the Steering Group would like your views on whether and how these
criteria and processes might be changed, and whether the existing safeguards, which ensure
the confidentiality of all personal data held by ONS, are sufficient. Responses to this
consultation will inform the Steering Group’s decisions on which should be pursued, dropped or
modified. Recommendations will be presented to the National Statistician for a final decision.
1The
Section of the SRSA regarding Approved Researchers is available here: http://www.legislation.gov.uk/ukpga/2007/18/section/39
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1.1 Current Process and Criteria
To be granted Approved Researcher status, the researcher and their project proposal are
considered at the same time, using a set of broad criteria published on the ONS website.
These state that the researcher is considered “fit and proper”, and can be approved, when they
demonstrate that they:
 Have the appropriate knowledge and experience necessary for handling potentially disclosive
personal information;
 Have provided satisfactory evidence supporting their application that illustrates their
professionalism and technical competence to carry out the research proposal; and
 Have a commitment to protecting and maintaining the confidentiality of the data during the
creation of outputs and publications that arise during the proposal.
The research project can be approved when it is deemed to deliver a public benefit in one of the
following ways:
 Supporting the formulation and development of public policy or public service delivery; or
 Forms part of the programme of research covered by the National Data Strategy or otherwise
supported directly or indirectly by the Economic and Social Research Council; or
 Supports an obligation of public law (e.g. Local Development Plans); or
 Explores new statistical methods that can be used to produce statistics that serve the public
good.
If both the researcher and project are deemed suitable, then Approved Researcher status is
granted for the duration of the project.
In addition to providing information that will be used to assess against the criteria, researchers are
required to provide their name, and the name and contact details of the Employer/Institution they
will work for when completing this project. This information is collected, as any sanctions applied
for a breach of the Approved Researcher Terms and Conditions could be applied to the
researcher’s employer, not just the individual.
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1.2 Current Data Protection Safeguards
In addition to strictly controlling access to its Microdata, ONS ensures the confidentiality of these
data in a number of ways:
 Data available for analysis are usually anonymised, with direct identifiers (e.g. Date of Birth or
Name of a Person or Business) removed.
o
In cases where retention of identifiers has been approved, these identifiers are only
used to link different data sources together to produce a dataset prior to analysis.
They are never analysed or reported on themselves.
 Use of a secure environment (e.g. the ONS Virtual Microdata Laboratory) required for analysis
of most datasets.
o
Training in use of environment required prior to access being granted.
o
Nothing can be removed from secure environment by researchers – ONS staff will
release results of analysis, once reviewed and confirmed as non-disclosive.
 Data can only be used for the specific purpose agreed during the Approved Researcher
process.
o
Any subsequent potential uses identified require a new application.
 Data can only be used by the named researcher who has been approved for that project.
o
Onward dissemination or data sharing of secure data ONS makes available to
Approved Researchers is not permitted under any circumstances.
 No attempt may be made to identify an individual, household or business using these data.
 All access to data will be withdrawn at the conclusion of the agreed project timetable.
 Any breach of these terms, whether deliberate or accidental, will result in sanctions being
introduced which can include:
o
The researcher having their Approved Researcher status revoked.
o
The researcher being banned from access to any ONS microdata for a period of
time or permanently.
o
The researcher being banned from access from other bodies which give access to
legally protected data for a period of time or permanently.
o
In some cases, researchers who are banned from access to ONS microdata, may
also lose the financial support of other organisations, e.g., Research Councils.
o
Sanctions being applied to all researchers from the offender’s employer or Research
Organisation.
In addition to these restrictions and sanctions, all data that require Approved researcher status to
access are protected in law. The unlawful disclosure of any personal information accessed in this
way is a criminal offence, punishable by a fine and up to two years imprisonment.
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Since the introduction of the Approved Researcher scheme in 2008, there has been no disclosure
of personal information by those accessing ONS microdata and, therefore, no prosecutions.
2. Proposed changes
In addition to seeking comments on the current criteria and process, which will inform the final
recommendations to the National Statistician, the Steering Group would also like views on a
number of specific and possible changes that are being considered. Each proposal would help
address a specific limitation identified by ONS, its users or other organisations who provide similar
access to data.
Proposal 1:
Current Process:

The existing process requires an individual and their research proposal to be considered at
the same time, and Approved Researcher status is then given for the individual to work on
that project.
Limitation identified:

This creates a significant administrative burden for ONS and applicants under the scheme.
o
Individuals wishing to work on more than one project must be approved separately,
and provide evidence of their research experience, each time.
o
ONS must then evaluate the suitability of the individual each time, often many times
in a year.
ONS are proposing to:

Approve individuals and their research projects separately.
This would mean that:

Individuals who work on more than one project would only need to be approved once, and
their Approved Researcher status would last for a fixed period of time (to be determined),
before renewal would be required.

Approved Researchers could work on multiple approved projects within that time period.

Each research project would continue to require separate approval to ensure that would it
would be an appropriate use of ONS data, and of benefit to the UK.
Proposal 2:
Current Process:
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
The existing process assumes that research projects will require access to one “instance”
of a dataset (for example, survey data from a specific quarter or year).
Limitation identified:

Some users would like access to an on-going time-series of data, to keep analyses relevant
and useful, and maximise their benefit.
ONS are proposing to:

Allow projects to request “on-going” access to a dataset, as new instances become
available, for an agreed period of time (for example, data for each quarter for three years).
This would mean that:

Approved Researchers could refresh or update their results when new data become
available, without a new project application.
Proposal 3:
Current Process:

ONS does not currently approve requests from individuals who are based outside the UK.
Limitation identified:

Researchers based outside the UK would like to carry out research which would serve the
public good, and would be willing to visit a UK-based secure environment to do so.
ONS are proposing to:

Allow individuals from overseas to apply for Approved Researcher status and propose
research projects of benefit to the UK.

Only approve these research projects when they are undertaken within a secure
environment within the UK, in order to retain control of the data and clearance of all
analyses prior to publication.
This would mean that:

Individuals who wish to complete a research project using ONS data, but who are based
overseas, would be permitted to do so where ONS are sure that it would be of clear benefit
to the UK.

Research projects involving separate analysis of data from ONS and other National
Statistics Institutes would be possible, which would facilitate international comparisons.

No ONS data would be passed to a researcher overseas. Data would only be accessed
through an approved secure environment in the UK. Only results which had been vetted
could be approved. (Microdata can never be removed).
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Proposal 4:
Current Process:

The current criteria require individuals to demonstrate their research experience before
Approved Researcher status can be given, which means that university students (for
example) who wish to use ONS data find it hard to be approved.
Limitation identified:

Academic researchers often wish to be supported on research projects by research
assistants or students, and can provide appropriate oversight and guidance of their work,
but this is not currently permitted.
ONS are proposing to:

Allow individuals without the required level of previous research experience to be granted
Approved Researcher status, provided that they only work under the support and direction
of another researcher who meets the requirements set out in Proposal 5.

The supporting Approved Researcher would be the “Lead” researcher on the project, and
that individual, or the supporting organisation, would have responsibility for ensuring that
the data were used appropriately and securely at all times.
This would mean that:

Undergraduate students would be able to analyse ONS data, provided their work was
supported and directed at all times by an experienced Approved Researcher.

Such access would only be given once an experienced Approved Researcher had asserted
their approval of the inexperienced researcher and that either they, or the relevant
supporting organisation were prepared to take responsibility for the work of the applicant.
Proposal 5:
Current Process:

The current criteria do not clearly specify what level of research experience is required for
an individual to be granted Approved Researcher status.
Limitation identified:

Applicants are not clear of the level of experience required, and often provide insufficient
detail.
o
Without sufficient evidence, ONS cannot approve an application, which delays the
process.
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
As the criteria are not specific, it is difficult for ONS to demonstrate that its decisions to
grant Approved Researcher status are consistent and objective.
ONS are proposing to:

Require individuals to have either:
o
A relevant undergraduate degree or qualification including a significant statistical
research component; or
o
At least three years’ experience working in a statistical research environment; or
o
The written agreement of an experienced Approved Researcher to supervise, to
lead or supervise the proposed research.
This would mean that:

ONS would be clear about the level of the research experience which any individual
applying for Approved Researcher Status had.

ONS would be able to demonstrate that its decisions to grant Approved Researcher status
were consistent and objective.
Proposal 6:
Current Process:

The current criteria require individuals to demonstrate their professionalism and
commitment to maintaining the confidentiality of ONS data at all times, but do not clearly
specify how this will be judged.
Limitation identified:

Individuals do not currently have a clear understanding of ONS’s requirements until their
application is processed.
ONS are proposing to:

Make the current requirements clear, before the application process is started. The current
requirements, which would be made explicit are that ONS:
o
Require individuals to undertake user training to ensure they have an understanding
of why data must be accessed safely and the penalties for misuse; understanding
how to prepare non-disclosive outputs for release and using the secure setting.
o
Require individuals to sign a User Agreement committing them to all relevant
requirements governing data access, data handling, training and output checking,
and confirming that they understand the legal protection given to ONS microdata
and the penalties for misuse.
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o
Ensure that where evidence of an individual’s misuse of data existed, they would be
denied Approved Researcher status.

This would include evidence from other bodies which give access to legally
protected data (for example, secure environments at the UKDS or HMRC
Secure Laboratory).
This would mean that:

Individuals who wish to be granted Approved Researcher status would have a clear
understanding of ONS’s requirements.

ONS would be able to demonstrate that its decisions to grant (or deny) Approved
Researcher status were consistent and objective.
Proposal 7:
Current Process:

The current criteria require research projects to demonstrate that they serve the public
good in one of four ways (shown in section 1.1).
Limitation identified:

As the range of uses and users of ONS data has broadened since 2008, this has been
reflected in applications for Approved Researcher status.
o
Some project requests do not fit within one of the four current categories, and
cannot currently be approved, even if they would serve the public good.
ONS are proposing to:

Update and clarify the definition of “public good” that must be satisfied for a project to be
approved, so one or more of the following must be demonstrated:
o
To provide an evidence base for public policy decision-making or public service
delivery;
o
To provide an evidence base for commercial decisions that benefit the UK economy
or society;
o
To replicate, validate or challenge Official Statistics;
o
To replicate, validate or challenge existing research based on these data;
o
To provide a contribution improving the economic competitiveness of the UK
o
To provide a contribution improving the quality of life of people in the UK
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
o
Extending the public understanding of social or economic matters by improving
knowledge or challenging widely accepted analyses;
o
To improve the quality or coverage, or presentation of existing statistical
information;
Allow for the approval of “speculative” research projects that are judged likely to serve the
public good using the above criteria, even where no specific use has been confirmed (for
example, analysis that would be likely to inform public service delivery, but not undertaken
or commissioned by a specific Government Department).
This would mean that:

Approved Researchers who wish to analyse ONS microdata would have a clear
understanding of ONS’s requirements.

A wider range of uses of ONS microdata would be understood to serve the public good
than is currently the case.

ONS could demonstrate that its decisions to approve (or deny) research projects were
consistent and objective.
Proposal 8:
Current Process:

Approved Researchers are currently only allowed to profit from their analyses of these data
when they are commissioned to work on behalf of a public body and are paid to do so.

Greater clarity is needed about the likelihood that an individual or organisation, with the
intention of selling the results of their analysis to unidentified customers, would be granted
Approved Researcher Status.
Limitation identified:

Research organisations within the Private Sector would like to undertake analysis using
ONS microdata, and sell their results to bodies that would use them to serve the public
good.
o

For example, undertaking analysis of data on commuting flows and selling the
results to Local Authorities to improve the planning and provision of public transport.
Such projects cannot be approved using the current interpretation of the Approved
Researcher criteria.
ONS are proposing to:
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
Allow the speculative analysis of ONS microdata with the intention of making a profit, where
ONS believe that profit would be generated by the sale of the results of analysis only, and
never the sale of the underlying data.

ONS would only grant such access when satisfied that the research project would serve the
public good, and not compromise any of the existing safeguards.
This would mean that:

Approved Researchers would be able to make more use of ONS’s microdata than is
currently the case.

ONS would continue to only allow research projects likely to serve the public good, but
would not restrict the ability to generate a profit while doing so.
Proposal 9:
Current Process:

ONS maintains a record of all Approved Researchers, but this is not publicly available.

There is no requirement for Approved Researchers to publish the results of their research.
Limitation identified:

The current process is not transparent – It is not possible to see who is using ONS
microdata, or for what purposes.

The results of analysis using ONS microdata are not always easily available, which could
limit their benefit.
ONS are proposing to:

Publish the list of all Approved Researchers, alongside a summary of their active research
project(s) on the ONS website.
o

Require the publication of results or outcomes of research projects within a set time period
(to be determined) of their completion.
o

Only the name and organisation of Approved Researchers at the time of the
application would be published.
Link to these published results from the ONS website where possible.
Grant Approved Researcher status only to individuals who accept that such information will
be published and maintained as a public record indefinitely.
This would mean that:
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
ONS would keep a record of all approved individuals and projects available for public
scrutiny.

Other bodies which give access to legally protected data could review this record to check
the status of any individual.

The results of research undertaken by Approved Researchers would be widely available, to
maximise their use.
None of the proposals in this section are certain to be presented to the National Statistician, and
the responses to this consultation will inform the Steering Group’s decisions on which should be
pursued, dropped or modified.
3. Method
 This consultation will run from 26 February 2015 – 29 March 2015
 There are 18 questions as part of an online survey
 The consultation response form is available electronically at:
o
https://www.surveymonkey.com/s/XJJLH7Y
 Responses to this consultation can also be submitted by post or email to:
Access to Data team
Office for National Statistics – Room 4200E
Segensworth Rd
Titchfield
Hants
PO15 5RR
Email: Access2Data@ons.gsi.gov.uk
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4. Consultation Questions
ONS would like views from its users and other interested parties in the following areas:
Proposed changes:
 Question 1, relating to Proposal 1: Do you agree that the approval of individuals and their
research projects should be separated?
o
What time period do you think most appropriate before Approved Researcher status
would require renewal? Please include your reasons.
 Question 2, relating to Proposal 2: Do you agree that research projects that serve the public
good, but require “on-going” access to do so, should be approved once and not many times?
o
What time period would you think appropriate before a new application would be
required to maintain access?
 Question 3, relating to Proposal 3: Do you agree that ONS should allow applications for
Approved Researcher status from individuals based outside the UK?
o
If not, please explain your reasons.
 Question 4, relating to Proposal 4: Do you agree that ONS should allow applications for
Approved Researcher status from individuals with little research experience, so long as they
have appropriate supervision?
 Question 5, relating to Proposal 5: Do you think that the proposed clarification of the level of
research experience required is reasonable?
o
If you think the requirements are too lenient/restrictive, please outline what you
would think more appropriate.
 Question 6, relating to Proposal 6: Do you think the proposed clarification of how ONS would
like individuals to demonstrate their professionalism and commitment to data confidentiality is
reasonable?
o
If you think the requirements are too lenient/restrictive, please outline what you
would think more appropriate.
 Question 7, relating to Proposal 7: Do you think the proposed clarification of what types of
research project ONS understand as serving the public good is reasonable?
o
If you think any of the proposed examples of “public good” should be removed or
modified, please outline which.
o
If you think there are better ways of defining public good in this context please
include them here.
 Question 8, relating to Proposals 5-7: Do you think the Approved Researcher process would
be simplified or improved by ONS clarifying its expectations in this way (even if you disagree
with the detailed proposals)?
 Question 9, relating to Proposals 7&8: Do you think that “speculative research” should be
permitted if it is not immediately clear that they will serve the public good?
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 Question 10, relating to Proposal 8: Do you think that the sale of the results of such analyses,
should be permitted provided that projects are judged to serve the public good?
 Question 11, relating to Proposal 9: Do you have any comments or suggestions with the
proposal to maintain a public record of all Approved Researchers and their projects?
 Question 12, relating to Proposal 9: Do you agree that ONS should only grant Approved
Researcher status to individuals who are content to be included on this record?
 Question 13, relating to Proposal 9: Do you agree with the proposal to require some public
publication of the results of all approved research projects?
 How soon after the completion of a research project should results be published?
 Question 14, relating to all Proposals: If you have any other comments on these proposals,
please record these and indicate which proposal(s) you are referring to.
General:
 Question 15: Do the current criteria and processes cause you any significant problems in
accessing the data required, which would not be addressed by the proposals in this paper?
o
If so, please explain how.
 Question 16: Do you think that the safeguards used to ensure the confidentiality of all data held
by ONS are appropriate/sufficient?
o
If not, are they insufficient or too restrictive?

Please suggest how they could be changed
 Question 17: Should the Approved Research criteria be promoted as the default access
mechanism for all relevant bodies which give access to legally protected data?
 Question 18: Do you have any other comments on the Approved Researcher criteria, process
or safeguards?
If you respond to this consultation by post or email, please also provide your Name and
Organisation details.
After the consultation
We will publish details of the updated Approved Researcher criteria and processes, including a
summary of the comments made during this exercise, approximately twelve weeks after the
consultation closes.
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Getting in Touch
If you have any queries or comments about the consultation process, please email Simeon Bowen
at ons.communications@ons.gsi.gov.uk or call 0845 601 3034.
You can also write to us at the following address:
Consultation Coordinator,
Room 1.101
Office for National Statistics,
Government Buildings,
Cardiff Road,
Newport,
South Wales,
NP10 8XG.
For further information on ONS consultations, please visit http://www.ons.gov.uk/ons/aboutons/get-involved/consultations/index.html
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Confidentiality and data protection
The basics…
As someone who is interested in ONS statistics, we’d welcome your views. We may ask you to tell
us who you are so that, where appropriate, we can follow up on the feedback you give. To
promote greater transparency, ONS may want to attribute some comments to the respondent
providing them in the summary to be published after completion of the exercise. If you do not wish
your name or organisation to be identified in this way, please indicate this in your consultation
response.
The details…
The information you send us may be passed to colleagues within ONS and other parts of
Government.
Information provided in response to this consultation, including personal information, may also be
published in accordance with access to information legislation including the Freedom of
Information Act 2000 (FOIA).
If you want the information that you provide to be treated as confidential, please be aware that,
under the FOIA, there is a statutory Code of Practice with which public authorities must comply.
This Code, amongst other things, deals with confidentiality. Because of this it would help if you
gave us a short explanation of why you think confidentiality is necessary. If we receive a request
for disclosure of the information we will take full account of your explanation, but we cannot give an
assurance that confidentiality can be maintained in all circumstances.
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Accessibility
All material relating to this consultation can be provided in braille, large print or audio formats on
request. British Sign Language interpreters can also be requested for any supporting events.
Crown Copyright
© Crown copyright 2015
You may re-use this document/publication (not including logos) free of charge in any format or
medium, under the terms of the Open Government Licence v3.0. Where we have identified any
third party copyright information you will need to obtain permission from the copyright holders
concerned.
To view this licence visit:
https://www.nationalarchives.gov.uk/doc/open-government-licence/version/3/
email psi@nationalarchives.gsi.gov.uk
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