You asked

I would like to ascertain:

1. What criteria you used to determine whether to send out a paper copy of the census or simply an online access code.

2. What steps you took to ensure you were not directly or indirectly discriminating against people based on protected characteristics.

3. What regard you had to the Equality Act 2010 and how you arrived at any conclusions in relation to your obligations under this statute.

4. Please also provide any minutes in relation to meetings regarding the above.

We said

​Thank you for your request. Please see the following answers to your questions:

1.     What criteria you used to determine whether to send out a paper copy of the census or simply an online access code.

Although Census 2021 is designed to be a digital-first census and we have been encouraging people to complete online where possible, the Office for National Statistics (ONS) has been making sure that those who do not have internet access, or would prefer to answer on paper, are aware of the census and how they are able to take part.

Our strategy to determine who initially received paper questionnaires and who received a letter with an online access code was based on our strategy to maximise response. Key to our design was to ensure that everyone would have access to a paper questionnaire should they wish to respond that way. All paper questionnaires also contain access codes to enable householders to respond online if they choose to do so.

Anyone can request a paper questionnaire via the website or contact centre. Those households who have not completed online have been offered paper questionnaires at some point during the operation. This is either because a paper questionnaire was posted out to them, or because census officers have provided them when making visits to those households.

The routes to getting a paper questionnaire are as follows:

  • As part of the invitation letter to take part in the Census in certain areas
  • Posted out as a reminder to all households that haven't yet responded in certain areas
  • On request through the contact centre or website
  • On request from or offered by a census officer. All census officers carry paper questionnaires and can also order questionnaires to be posted out (if they have run out, for example)

Our Census Support Centres are also available to help anyone complete online if they wish to do so but need some support, along with targeted provision of telephone capture if necessary. Details of how to contact these centres is provided in the initial contact letter and our website.

Our strategy is to ensure that everyone has the means to respond in the manner in which they choose, while ensuring that we make the most effective use of our resources. The difference between 2011 and 2021 is that some areas would previously have had high levels of response before the follow-up period started but might now struggle with completing their Census online. To mitigate for this and to ensure that we don't have a larger pool of households in our follow-up workload (including those that are willing to respond but didn't have the means to do so), we are targeting our initial delivery of paper questionnaires at those areas which have a high willingness to respond but a low digital uptake.

We recognise that there are other areas where there is likely to be high digital exclusion in areas of greater deprivation, but as these areas were less likely to respond in 2011 even when they were sent a paper questionnaire, we know that sending a paper questionnaire as initial contact is not likely to be the most effective way to provide them with paper. Instead, we can provide them with paper questionnaires when we make contact on the doorstep. We also posted out paper questionnaires as a reminder to all households who hadn't yet responded in certain areas. We believe that this combination of sending paper questionnaires earlier to those who are likely to respond without further prompts, and sending them later in the operation to those who are more likely to receive field visits and reminder letters, is the most effective strategy to ensure that we are targeting paper at areas where, and at a time when, it is most likely to have the greatest impact.

Exactly which areas were targeted with paper questionnaires as their initial contact and as a reminder was determined by an index, which looks at a series of relevant data sources to determine the propensity of households in a particular geographic area (Lower Super Output Areas) to respond without follow-up interventions (such as field visits and reminder letters) and their propensity to respond online. Further detail on how we developed the index and our specific strategy can be found in our Maximising Response in Census 2021 webinar and our published paper on the Statistical Design for Census 2021.

2.     What steps you took to ensure you were not directly or indirectly discriminating against people based on protected characteristics.

3.     What regard you had to the Equality Act and how you arrived at any conclusions in relation to your obligations under this statute.

Public sector bodies must, under the Equality Act 2010 (the Act), have due regard to the need to:

  • eliminate discrimination, harassment, victimisation and any other conduct that is prohibited by or under the Act;
  • advance equality of opportunity between persons who share a relevant protected characteristic1 and person who do not; and
  • foster good relations between persons who share a relevant protected characteristic and persons who do not.

The ONS has published an Equality Impact Assessment (PDF, 676.7KB) for the 2021 Census as part of this process. The assessment outlines our commitment that "*Paper forms will be available to any who need or want one*" and demonstrates our due regard to ensuring that Census 2021 would not, directly or indirectly discriminate against people based on protected characteristics.

4.     Please also provide any minutes in relation to meetings regarding the above:

The decision on the paper/online initial contact was made at a range of meetings over a number of years. This included the technical development of the approach and review of the data we used to make the decision. Therefore, in order to ensure that we have fully answered your request for the minutes of meetings referring to this request, we would need to search through documentation spanning a number of years and covering a range of topics, including the technical development of the approach, the review of the data we used to make the decision (including with data suppliers and the legal requirements we met to do this), and preparations for the 2017 test and 2019 rehearsal, which was part of the development of the approach. A range of meetings would also need to be searched where this process was discussed with other areas of the operation with suppliers and internally with the teams involved. The cost limit for replying to a Freedom of Information request is £600 or 24 hours work, and in our view we would need to exceed this in order to answer your request to locate and extract this information.