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Dissemination - Misrepresentations of Graduate Outcomes data

Misrepresentation is the action of giving a false or misleading account of the nature of something. Misrepresentation may occur unintentionally and can arise through misunderstanding. Intentionality does not materially alter the need to intervene in response to misrepresentation but should be taken into account in determining the form of any intervention. HESA maintains an extensive range of user support to promote appropriate and responsible use of its data, but misrepresentations do sometimes occur.

HESA cannot take responsibility for the decisions of external parties over their use of our statistics. Neither do we seek to be an arbiter of debates over policy and practice in the domains where we publish, nor do we possess the resources to proactively police and assure all external uses of our data. HESA does, however, recognise the potential risks to (and serious impacts on) the perceived trustworthiness, quality, and value of its statistics, in cases where they are cited as supporting invalid conclusions or interpretations.

With regard to HESA’s statistics, misrepresentation is deemed to have occurred if any of the following statements is true:

  • The advice of statistics professionals has been ignored.
  • HESA statistics that are used in a document or statement by an external party, are presented in such a way that (in the Agency's opinion) they are liable to mislead the public or undermine the integrity of official statistics.
  • Information has been circulated which is falsely claimed to derive from HESA, or might reasonably be misinterpreted as HESA data by users.

When we become aware of such cases of misrepresentation, we will evaluate the risks, and may choose to intervene. We may choose to do this in a variety of ways, depending on the circumstances. The first step will normally be to discuss the issue with the party believed responsible for the misrepresentation. Where the organisation recognises that a mistake has been made, undertakes to clarify an aspect of the statistics promptly, and does so in line with our advice, then we can decide that one (or more) of the following courses of action applies:

  1. No further action at all is required.
  2. No public letter need be written, but a private letter will be written.
  3. A simple public message welcoming the clarification is published by HESA.

Where initial engagements do not achieve the desired outcomes, the following further options are open to HESA:

  1. Publicising the fact that a suspected misrepresentation has come to our attention, and that we will be looking into the matter.
  2. Publishing a clarification of our own, referencing the misrepresentation.
  3. Writing a public (published) letter to the person or organisation responsible for the misrepresentation, informing them of the error, and explaining both why this is a misrepresentation, and the seriousness of the matter.
  4. Writing to the regulator (or other authority) most relevant to the professional domain of the organisation held responsible for the misrepresentation, or of the forum in which the misrepresentation occurred.
  5. In the most serious cases, where the actions above have been exhausted and are still deemed insufficient, HESA’s Board can decide to take further actions, for example:
    • Seeking advice from the National Statistician, or their Data Ethics Committee.
    • Referring the matter for investigation by the UK Statistics Authority’s Office for Statistics Regulation.
    • Where permissible and feasible, imposing sanctions on future access to data.
    • Any other lawful and reasonable measures.

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