The University f Kent Crprate Standards fr data quality and the cllatin f data fr external presentatin This paper intrduces a set f standards with the aim f safeguarding the University s psitin in published infrmatin, while at the same time building cnfidence in data and its rbustness fr analysis. These standards apply t quantitative as well as qualitative (textural) data held in universitywide systems and submitted externally. The Audit Cmmissin s publicatin Imprving infrmatin t supprt decisin making: standards fr better quality data (2007) is acknwledged. Cntext A specific bjective that targets data quality in islatin is unlikely t result in high quality data. Such quality is the utcme f a seamless prcess f an rganisatin s peratinal and perfrmance management and gvernance arrangements. In particular the prcesses fr independent data review and signff f all externally transmitted data, prcedure ntes, audit, resilience and backup, tgether with staff training and setting clear respnsibilities will all cntribute t creating the apprpriate culture within which data accuracy has a visible imprtance and can flurish. It is frm such a culture that high data quality results. In applying these standards, heads f Prfessinal Service Departments will need t cnsider the risk, including the ptential future risk, f data in individual returns impacting n the University s reputatin and/r finances. Returns with a high risk will require a higher level f management and scrutiny than thse with lw risk. Gvernance and Leadership Althugh Cuncil hld ultimate respnsibility fr data quality assurance, it is the day-t-day respnsibility f individual members f staff t ensure that the principles f this plicy are fllwed t maximise the accuracy and timeliness f data returned externally. The University will require a culture that demnstrates a high cmmitment t data quality at a senir level. A culture derives frm a strng rganisatinal lead supprted by a sund rganisatinal mdel. Three principles shuld dminate this cmmitment: That the University shuld publish a Crprate Standards fr Data Quality plicy that demnstrates a clear cmmitment t a culture f data quality thrughut the University. Strategic respnsibility fr data quality shuld be part f the frmal prtfli f a member f the Executive Grup (EG). An bjective that all data and data returns shuld aim fr the highest pssible standards f accuracy shuld be established t set a clear expectatin f the standards required by the Executive Grup. All users f statistical data held n University systems shuld be aware f the key principles f data prcessing cntained in the Data Prtectin Act (1998). Page 1 f 6
Crprate Objectives fr Data Quality The University f Kent will prcess data in accrdance with Schedule 1 f the Data Prtectin Act (Appendix 1) and, in the cntext f this plicy, issues f relevance, timeliness and validity are particularly pertinent. The University f Kent, in cmmn with ther Universities, needs cmplete, accurate and reliable infrmatin in rder t manage its business, including: Delivering an efficient service t staff, students and stakehlders Prviding infrmative and reliable management infrmatin and reprting Demnstrating public accuntability Presenting a respnsible and true public face. The principal reasns why data supplied externally by the University shuld be f the highest pssible quality are: The external presentatin f the University has assumed greater significance in the cntext f increased tuitin fees. Ptential applicants, their parents and their advisrs lk increasingly t the perfrmance f the University acrss a range f statistics in deciding whether t invest significant sums f mney. Our perfrmance is cmpared with ur peers, s it is vitally imprtant that the University s external image, as reflected in the data published abut us (that feeds these cmparisns), shws the University in the best pssible light. T ensure accurate funding allcatins fr bth teaching and research (data supplied by the University t HEFCE and HESA affects the funding that the University receives). With the increasing reliance n perfrmance management and assessment regimes, it is imprtant t be able t demnstrate the reliability and rbustness f the underlying data. Gd quality data and external data returns reflects a well-run institutin and this is likely t influence the University s external credibility. The HEFCE Mdel Financial Memrandum between HEFCE and institutins (HEFCE 2010/19, Annex B) intrduced a new requirement fr the Audit Cmmittee t give, as part f its annual pinin, assurance ver management and quality assurance f data submitted t HESA and t HEFCE and ther funding bdies. Data Scrutiny & Review The need fr data items shuld be peridically reviewed t ensure the data is necessary and that it is cllected in the mst efficient frm. Wherever pssible, data held n university systems shuld be: subject t n-line validatin at the pint f entry; subject t verificatin by the data subject (where apprpriate). All data held n University systems shuld be scrutinised n an n-ging basis fr reasnableness, accuracy and fitness fr purpse with extensive exceptin reprting t identify pssible data errrs r missing values. Page 2 f 6
Cmpilers f external returns shuld pay particular attentin t the fllwing: Cmpleteness f data sets and missing data issues; Time series / data trends, as an aid t understanding cntext; Critical appraisal f data abnrmalities with explanatins dcumented. The need t cnsult ther relevant departments and individuals t gain necessary cnsensus befre finalising the return. Independent review A thrugh assessment f data t be returned externally shuld be undertaken by a senir persn nt invlved in the cllatin f the return preferably a Prfessinal Service Department Head r equivalent. The relevant head f a Prfessinal Service Department shuld evaluate summary statistics fr each set f data returned externally: fr reasnableness; fr cntext in terms f summary statistics fr previusly submitted data. Help shuld be slicited frm an apprpriate ffice (i.e. Planning and Business Infrmatin Office) shuld the necessary technical skills t undertake this wrk, nt be available t a Prfessinal Service Department Head. Final review and signff As a minimum, the EG member respnsible fr the apprpriate Prfessinal Service Department will then undertake a high level check fr credibility and reasnableness befre signing ff the data return. Prcedure ntes Prcedure ntes shuld infrm each external return - peridically updated t reflect mst recent instructin and practice. Prfessinal Service Heads shuld ensure that all such prcedures are adpted and embedded within wrking prcesses t achieve cmpliance. Resilience and Backup Organisatinal resilience shuld be delivered thrugh ensuring that each data return can be cmpiled by a least tw cmpetent and fully trained members f staff preferably each with practical experience f undertaking the return thereby minimising the expsure t risk in the event f staff unavailability. Staff training and Setting Data Respnsibilities Staff respnsible fr undertaking data returns shuld be apprpriately trained in the necessary technical skills t undertake the wrk as well as having an understanding f the cntext and specifics f the return. Respnsibilities fr data accuracy shuld be included in jb descriptins fr thse staff with significant management respnsibility r where data handling frms an imprtant part f the rle. Page 3 f 6
All members f staff shuld understand their rle in cntributing t gd quality data as well as their individual respnsibilities and be aware f the implicatins f pr data quality bth within the institutin and externally. Members f staff shuld be encuraged t reprt immediately t their manager if data quality issues are identified. The manager will undertake apprpriate actin t remedy the situatin. Audit and Reprting Each ccurrence f the external submissin f data shuld demnstrate transparency between summary statistics derived frm the data t be reprted externally, and the summary data set held in internal systems, with a full recnciliatin analysis fr any differences fr each return. Each external return shuld be supprted by a dcument setting ut a clear, cmplete and verifiable audit trail. It shuld als enable cnfirmatin that the methdlgy emplyed meets relevant requirements. Internal audit will carry ut wrk t supprt the Audit Cmmittee s requirement t reprt as part f its annual pinin n the management and quality assurance f data. This wrk will include a cnsideratin f the applicatin f these standards and a review f selected returns. The DVC with respnsibility fr the Crprate Standards fr Data Quality will reprt annually t Audit Cmmittee. The cntent f this reprt will infrm the University s risk management prcess. Heads f Prfessinal Service Departments will be required t maintain a risk assessed list f external data returns undertaken by their department and reprt annually t the chair f Cuncil in rder t infrm the risk management prcess. All external returns shuld cmply with the Crprate Standards fr Data Quality. Fr high risk data returns, a checklist shuld be cmpleted t prvide assurance t the Executive Grup member and the University that the return has met the minimum standards implied by the Crprate Standards fr Data Quality A peridic (biennial) review f the Crprate Standards fr Data Accuracy will be undertaken by the Executive Grup t ensure that they remain fit fr purpse. Summary f Key Actins Each Head f a Prfessinal Service Department shuld cmpile and maintain a list f the regular data returns made by his/her Department n behalf f the University, with an indicatin f the risk generated by each return in terms f reputatin. Each Prfessinal Service Head shuld ensure that a set f prtcls (in the frm f prcedure ntes) is maintained fr each regular external return. Page 4 f 6
A summary f each regular external return shuld be apprved by the Executive Grup member respnsible fr the area cvered by the return. Additinally the Vice-Chancellr may be required t sign ff the return as Head f Institutin. Each Prfessinal Service Head shuld ensure that there is adequate cver in the specialist skills and knwledge necessary t cmplete each external return. Each new external demand fr data shuld be reviewed frm a perspective f the external implicatins and the Executive Grup member respnsible alerted. This implies that the data return will be summarised and evaluated against previus r similar data returns. Data returns, and cmpliance with this strategy, will frm part f the wrk f the internal Audit Team. Cntact Advice r questins cncerning this plicy r issues arising frm it, in the first instance, shuld be addressed t Dr Keith Lampard, Secretary t Cuncil, The Registry, Canterbury CT2 7NZ. Jc 17/07/13 Page 5 f 6
Appendix 1 Data prtectin principles Schedule 1 t the Data Prtectin Act lists the data prtectin principles in the fllwing terms: 1. Persnal data shall be prcessed fairly and lawfully and, in particular, shall nt be prcessed unless (a) at least ne f the cnditins in Schedule 2 is met, and (b) in the case f sensitive persnal data, at least ne f the cnditins in Schedule 3 is als met. 2. Persnal data shall be btained nly fr ne r mre specified and lawful purpses, and shall nt be further prcessed in any manner incmpatible with that purpse r thse purpses. 3. Persnal data shall be adequate, relevant and nt excessive in relatin t the purpse r purpses fr which they are prcessed. 4. Persnal data shall be accurate and, where necessary, kept up t date. 5. Persnal data prcessed fr any purpse r purpses shall nt be kept fr lnger than is necessary fr that purpse r thse purpses. 6. Persnal data shall be prcessed in accrdance with the rights f data subjects under this Act. 7. Apprpriate technical and rganisatinal measures shall be taken against unauthrised r unlawful prcessing f persnal data and against accidental lss r destructin f, r damage t, persnal data. 8. Persnal data shall nt be transferred t a cuntry r territry utside the Eurpean Ecnmic Area unless that cuntry r territry ensures an adequate level f prtectin fr the rights and freedms f data subjects in relatin t the prcessing f persnal data. Page 6 f 6