There are currently 391* (as of 12th December 2019) providers on the Office for Students’ register of higher education providers in England. For those that are not close followers of the expansion higher education they may be surprised by the large number, but it highlights the increasing diversity of type and size of provider.

In recent months I have spoken at a couple of conferences where I considered both the changing role of data in higher education management and also considered the Government’s Regulators Code, reflecting on regulation in England. I therefore wanted to take this opportunity to join these two presentations together and consider the use of data in higher education regulation.

It is worth remembering that the Regulators Code – which is the Government’s framework for regulators – says that “Regulators should choose proportionate approaches to those they regulate, based on relevant factors including, for example, business size and capacity.”

When thinking about the 391 providers on the OfS’s Register it is worth noting that fewer than a third of these providers have more than 7,000 students and that more than half of the providers have less than 1,000 students.

Data can be hugely powerful, and provide excellent insight into often highly complex organisations and the trend towards the greater and better use of data has been one of the key features of higher education management over the last decade. Indeed, the ability to use data is increasingly expected in the skillset to become a senior university manager.

However, it is important to note that for those institutions with small student numbers this quantitative approach to data should come with significant health warnings. The data can change significantly year on year due to a few students being more positive or negative, in many cases the datasets are not large enough to be statistically significant and even on their largest courses the ability consider specific groups of students or questions of intersectionality can make the datasets so small as to be meaningless. It should also be noted that whilst this is particularly true in smaller institutions it should also be considered in larger institutions with proposals to move to a subject-level TEF or PGT National Student Survey – all of which start to deal with much smaller student cohort numbers.

It was interesting when looking at the number of references to the word “data” in the OfS’s Regulatory Framework, that in the 166 pages of the Framework there were only 87 mentions. Indeed the Framework outlines that the “regulatory approach is designed to be principles-based because the higher education sector is complex…does not therefore set out numerical performance targets…Instead it sets out the approach that the OfS will take as it makes judgements about individual providers on the basis of data and contextual evidence.”

Based on feedback from members this perhaps might not reflect the experiences of many providers in recent months either going through the registration process, developing their Access and Participation Plan or through wider ongoing monitoring interventions with the OfS, where it feels like there is an over-emphasis on data, and particularly on data that is not statistically significant.

When I was at NUS we supported students’ unions to use the National Student Survey data and we constantly emphasised the importance of the qualitative data in the free-text comments. The OfS should reflect on how it is better able to assess institutions using a more nuanced, and more qualitative, approach – particularly for the large numbers of smaller providers that it regulates. When Universities Minister Chris Skidmore’s established his Data advisory committee in January 2019 he wanted the group to “help ensure the department is making the most of the opportunities presented by rich new datasets, and that they are being used in the best way possible” and this is a principle we would encourage the OfS to consider.

So whilst data can be hugely valuable for managers, governors and regulators to gain an insight into higher education providers it is important to see this data in context and consider what other information can be used to triangulate this with qualitative and external information to ensure intelligent regulation. It brings to mind the famous Francis Bacon quote about money, which I would amend to suggest that whilst data is a good servant, it is a bad master.

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