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Dissemination - Legal and Compliance considerations

On this page: Data Protection Act 2018/GDPR | Official Statistics | Freedom of Information 

The Jisc dissemination policy and practices for Graduate Outcomes data operate within the following compliance environment. We explain these compliance obligations because they set the terms within which our policies on publishing and otherwise disseminating data must operate. They therefore have a profound influence on the approaches we take.

Data Protection Act 2018/GDPR

Jisc collects identifiable personal data about students and graduates in and from UK HE. The majority of the data and information Jisc expects to disseminate around Graduate Outcomes in HESA-branded publications is drawn from both of these personal data collections.

Jisc takes its responsibilities around data protection extremely seriously and recognises that, beyond basic compliance with the law, Jisc data collection operations depend upon maintaining the trust and confidence of data subjects. Within our data dissemination activities, we focus a great deal of effort on reducing any risks to the confidentiality of individuals to the absolute minimum. We deploy tried and trusted approaches in achieving this, such as data minimisation, pseudonymisation, anonymisation (deploying statistical disclosure control) and contractual controls. Find out more about approaches used by Jisc.

Where more detailed data, such as microdata (i.e. data at a very detailed level that could pose risks to confidentiality of individuals), is required to support particular uses (such as academic and other research), data extracts will only be supplied by Jisc under a strict data sharing agreement which specifies how the data may be used, including the precise purpose, the permitted user(s), protections for data subjects, and the timeframe over which it is allowed to be retained. Data supplied under such terms must be destroyed once the permitted use has been completed. The agreement under which such data is supplied includes stringent requirements on data recipients to maintain information security and protect confidentiality of individuals. All uses must be compliant with the terms of the Data Collection Notices issued to data subjects.

Official Statistics

Jisc is a designated producer of Official Statistics as set out within the Official Statistics Order 2023. Jisc publishes a wide range of Official Statistics, such as Statistical Bulletins. Many of these are published under the HESA brand. In respect of our accredited official statistics (called National Statistics in the Statistics and Registration Service Act 2007) specifically (and by implication our wider Official Statistics outputs), we are under statutory obligation to comply with the Code of Practice for Statistics, which sets out a range of expectations on how producers should plan, design, construct and disseminate statistics based around core themes of trustworthiness, quality and value.

  1. Trustworthiness - Confidence in the people and organisations that produce statistics and data.
  2. Quality - Data and methods that produce assured statistics.
  3. Value - Statistics that support society’s needs for information.

One of the key requirements of the Code is that organisations should commit to releasing their statistics in an open and transparent manner that promotes public confidence. Access to statistics prior to general publication is strictly controlled under the terms of secondary legislation – the Pre-release Access to Official Statistics Order.

Under the Code, together with this Order, producers of official statistics and accredited official statistics must restrict access to unpublished statistics to those directly involved in the production and quality assurance process. The Order permits Official Statistics to be shared with a minimal number of ‘eligible persons’ (primarily Government Ministers and Senior Officials together with their advisors) no more than 24 hours prior to general publication. Jisc will normally accept requests to provide pre-release access to eligible persons where such requests are fully compliant with the Pre-release Access Order, subject to the requirement to keep the number of such persons to an absolute minimum. Access prior to publication is not made available to any other parties under any circumstances, and this includes members of the UK press and media.

Information on Jisc's compliance with the Official Statistics framework is available via our website.

The Office for Statistics Regulation (OSR) conducted a review of HESA’s experimental Graduate Outcomes publication during February and March 2021 (prior to the merger between HESA and Jisc), culminating in release of their findings on 18 March 2021. The OSR found a range of features which demonstrated the trustworthiness, quality and value of the statistics, and supported a range of further improvement work that HESA was already addressing at the time of the review.

In October 2023, the OSR began a further assessment of the Graduate Outcomes statistics’ compliance with the Code of Practice for Statistics. In April 2024, the OSR informed us of the outcome of their assessment, noting that the Graduate Outcomes statistics adhere closely to the Code of Practice for Statistics and can now be confirmed as accredited official statistics. 

Freedom of Information (FOI)

Jisc is not covered by this legislation as we are not a Public Authority under the Freedom of Information Act 2000. However, Jisc aims to support openness and transparency in its operations, and we publish extensive information via our website as well as responding promptly to reasonable requests for information.

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