Ensuring equity of access at time of release of market sensitive information
6.1 Identification of risks related to early access to market sensitive information
A number of official and National Statistics have a very high profile, and their release is often associated with significant market movements. The Office for National Statistics (ONS) must ensure that no individual or business that could profit from it, has pre-publication access to such information, and that practices are adopted to prevent them from abusing any such privileged pre-publication access.
Risks in this area are associated with statistical processes that follow on from processing and estimation, typically related to release processes. Risks are identified by studying the release processes for the major economic and social indicators, the environments in which they are stored prior to release, the people who have access to the information prior to its release, its method of delivery to them and the undertaking they make in relation to the security of the information.
The Code of Practice for National Statistics, and related guidelines, sets out the principles governing release of statistics. ONS also abides by the IMF's Special Data Dissemination Standards.
Many of the risks associated with the inappropriate release of statistics are incurred by those who have early access to the statistics for particular reasons. These people include ministers and their departmental staff and advisers.
Internal reviews, and the reviews undertaken under the National Statistics Framework, as well as any commissioned by the Statistics Commission, include dissemination aspects of the statistics in their potential scope. These reviews provide another mechanism for identifying risks in release practices.
6.2 Processes for judging the likelihood and impact of identified risks related to early release
The likelihood and impact of identified risks is assessed in the same way as the risk is identified. Assessment of the likelihood is made by the relevant statistical experts, based on past knowledge and experience, as well as international experience. In some areas, the likelihood might be informed by specific measures, such as the number of people with early access to the statistics, or the number of days between the finalisation of a figure and its publication.
The impact of risk is assessed on the basis of known uses of the data, past experience, the size of the problem, the nature of the statistical output and its use, and by discussions with users on the likely impact. The impact of early release of a statistic will depend on how different the figure is from market expectations. Risks associated with figures that are quite different from market expectations, and which therefore have yet to be factored into market prices, will have a higher impact and need to be dealt with particularly cautiously.
6.3 Processes for evaluating risk management strategies related to early release of key indicators
The review processes used to identify risks for pre-publication access to statistics also provide a means of evaluating past risk management strategies. Where a review picks up a problem with an aspect of an output, the problem is corrected. In addition, an effort is made to understand why the error initially occurred, and how the relevant risk should have been managed.
Where a problem arises, and after it has been solved, the business area is responsible for reviewing why the problem happened, drawing lessons from what went wrong and putting in place preventive action for the future. There is not currently a formal approach adopted by each area, but there would generally be a post-mortem that would involve reviewing the risk register to ensure the risk had been listed and analysing whether response actions could have been more appropriate. If the risk was not included on the register, the responsible area would be expected to consider why the risk had been missed and review both the risk register and risk identification procedures, to see if further risks of a similar type may also have been omitted.
The number of inadvertent pre-publication accesses to statistical information would be an indicator that could be used in evaluation of risk management process.
6.4 Involvement of stakeholders in management of risk of early release
The main stakeholders in the ONS risk management strategy relating to pre-publication access are users. A particular group of users are those who have early access for particular purposes, but are prohibited from using this information to their personal advantage. These people must be involved in the risk management strategy as they are an intrinsic part of the risk to be managed. Users who request early access are consulted about their particular circumstances, and the case for their access. Increasing the number of people with access to these statistics increases the risk of early release of the statistics and inappropriate use of the information in market trading.
Where new dissemination strategies are being developed, users without early access are consulted about the release arrangements used (including electronic release) and the security of these arrangements to ensure approaches are appropriate and any information on risks is obtained.
