The International Statistical Institute (ISI) and the International Association for Official Statistics (IAOS) have been informed of a decision in El Salvador, to dissolve the Dirección General de Estadística y Censos (DIGESTYC) and to transfer the functions of the National Statistical Office to the Salvadorian Central Bank. The corresponding law for the dissolution and transfer of the tasks of DIGESTYC, introduced at the end of July 2022 upon the initiative of the Government, has already been adopted by Parliament.
ISI and IAOS express their grave concern about the risks involved in this decision. The risks particularly relate to the mission of El Salvador’s official statistics as well as their professional independence, the qualification of staff and the confidentiality of statistical data.
As the decision-making process appears to be concluded, we call on the Government to make provisions so that the risks we have outlined in more detail below can be mitigated and, at best, avoided. Based on experience in the international statistical system, we suggest considering at least the following measures:
- The National Bureau of Statistics, now a department in the Central Bank, should be managed by a person with an adequate statistical profile. This manager of the statistics department should have a sufficiently high internal rank and should be granted professional independence in the execution of his or her tasks.
- It is crucial for confidence in the confidentiality of individual statistical data (microdata) that their misuse for political, administrative or for non-statistical Central Bank purposes is excluded. Organisational, technical and legal measures should therefore be taken to build a firewall to protect the confidentiality of microdata.
- The process of statistics production should be accompanied by two mechanisms:
- First, (‘upstream’) a process should be institutionalised, in which the stakeholders and users of statistics are broadly consulted in the priorities and planning of the statistical programme.
- Secondly, an independent procedure should (‘downstream’) regularly assess whether and to what extent the statistics have been produced according to the quality criteria and principles of good public statistics.
ISI and IAOS stand ready to support the government of El Salvador with professional experience, advice and practical assistance. We would welcome a dialogue in which we could explain the risks we have identified, answer questions about them and discuss the recommended measures.
Public statistics are the informational infrastructure on which debates and decision making rely for economic, social and environmental policies. Produced by the public statistical system, according to standardised rules and procedures, they are in fact necessary for policy formulation, as well as for monitoring and evaluation and eventually for identifying policy gaps, and subsequently in this case for policy revision. Through statistical surveys, including the population census and statistics using administrative sources, public statistics provide quantitative results, to evaluate and analyse the social, demographic, environmental, and economic situation for the benefit of a broad range of users in El Salvador.
This public statistical infrastructure can only fulfil its important role efficiently and effectively if the conditions for this are met, which are laid down in both the ISI “Declaration of Professional Ethics” and the UN “Fundamental Principles of Official Statistics”.
Public statistics are undergoing a rapid and profound change process to adapt to new opportunities and conditions. Digitalisation requires technical innovations, globalisation places demand on statistics beyond national borders, and the UN Sustainable Development Strategy can only be successfully implemented with modern public statistics. For middle- and low-income countries, this modernisation means an enormous challenge, which is why international institutions are providing financial, material and technical support.
The law explicitly refers to these objectives of modernisation as well as statistics for evidence-based policy and broad public discourse. However, the solution now chosen for this, to make the central bank also a statistical office as a secondary task, is very unusual in the international statistical system and raises some substantial questions:
- The law uses the Central Bank’s responsibility for macroeconomic statistics, such as National Accounts, as a testimony of its already existing statistical experience. However, this specific competence is of little relevance for the professional performance of public statistics tasks outside the narrow macro-economic spectrum of the statistical programme, especially for population, social and household statistics. The linking of traditional surveys with modern analyses of existing data could offer great potential for improving efficiency, if existing skills in designing and conducting surveys are enriched with contemporary data science. It is important that these skills be developed or acquired for the statistical office.
- The business assets of an institution in the information sector, such as a statistical office, essentially consist of personnel with their knowledge, competence and experience. It is all the more surprising that the law is silent on this and does not contain any qualified statements or make provisions for an orderly transition of the existing DIGESTYC staff. While the tangible and intangible assets in the liquidation process are taken care of in detail, there is no chapter on the transition of operational staff (such as field workers), professional statisticians and the previous management as well as their contractual and administrative position in the Central Bank.
- The Bank is now assigned the functions and responsibility for conducting all censuses, such as population, housing, economy and agriculture, as well as sample surveys and price indices. In addition, the Central Bank is given the powers to coordinate all economic statistics of the country. The decision on the statistical programme and its implementation is delegated to the Bank’s Board of Directors. We wonder what the consequences will be for prioritisation in the programme under narrow limitations if it is decided by the Central Bank, an institution whose tasks and political position are focused on economic policy. The requirement of statistics for the benefit of the entire population, which the law formulates, seems to be difficult to reconcile with this decision. A solution may be to have a separate Advisory Board, with an independent Chair, whose role is to provide advice on the Statistical programme and its implementation to the concerned parties.
- It is essential for the quality and credibility of public statistics that they are policy relevant without being politically driven. For the independence, objectivity and transparency of statistics, appropriate provisions must therefore be made in governance (public mandate, budget and licence), not least in the form of adequate institutional sovereignty with reference to administration and politics. How could this essential objective can be fulfilled if statistics is a sub-task of the central bank with the inevitable conflicts of interest between statistics and central bank policy that will arise some time in the future. An agreed arrangement should be introduced in the statistical legislation to delineate the procedure which would be applied independently to enable regular assessment of whether and to what extent the statistics have been produced according to the quality criteria and principles of good public statistics.
- National policy makers and international institutions are the main users of El Salvador official statistics. They should have full confidence in the reliability of official statistics that have to reflect properly national facts. They must be able to trust that the arrangements in place for collecting and compiling national statistics are of quality and free of political influence.
Although we very much support efforts to modernise statistics and are aware that their organisation and governance depend on national circumstances, we are concerned about the risks which if not appropriately managed, could damage the fulfilment of tasks for the benefit of El Salvador as well as harm the reputation of statistics both in El Salvador and internationally.
The Hague, 19 August 2022
ISI Advisory Board on Ethics