Freedom of Information Request – Consultation Submissions

What’s been said?

In response to a Freedom of Information Request the Department for Education have published the number of submissions they received in response to the English Call for Evidence concerning elective home education.

The following responses were received:

  • Online: 2,987
  • Email: 274
  • Hard copy: 180

The FoIR requested a breakdown of the number of individual respondents and those doing so on behalf of organisations. The DfE provided the following information about the online submissions:

  • Respondents identifying as individuals: 2,681
  • Respondents identifying as organisations: 224
  • Respondents who did not answer this question: 82

They also stated, “It is not possible to identify reliably the split between individuals and organisations for the responses made in other formats, as there was no request for identification as individual or organisation.”

Why does it matter?

First it is good to know that they received a significant number of responses – 3,441 in all – suggesting that a good number of HE families made the effort to respond to what was anything but a user-friendly consultation. The authors certainly ignored the first point in the government’s own Consultation Principles 2018 [PDF]. Under the heading “Consultations should be clear and concise”, this includes instructions to “Make them easy to understand and easy to answer. Avoid lengthy documents when possible and consider merging those on related topics.” (See also points F & G to further illustrate how these principles were ignored.) Given the number of people who responded, we believe it is right to say, “Well done, Team EHE.”

Secondly, it would be easy to assume that most of the individual responses were from HE parents, whilst the “organisations” were mainly local authorities and professional bodies in favour of registration and monitoring. The latter assumption may not be as overwhelmingly correct as the former. The HE Byte knows of several organisations which made submissions pointing out the flaws in the draft guidance documents, and we are sure there will be others. Three examples are Libertarian Party, Centre for Personalised Education and Christian Concern. We have also heard of local HE groups which were planning to make submissions, so the number of organisations responding was probably far from being completely supportive of the position put forward in the consultation.

Finally, we have highlighted previously The Education Secretary’s commitment that his department would listen to home educating parents who participated in the consultation. How that might come about is something of a mystery for the majority of the EHE community. One window of understanding opened up in mid-May when the DfE advertised for bids to process the text of the responses in a way which will make them “available in a form that allows us to complete further interrogation of the data.” Bids for the contract, worth between £15k and £35k, had to be submitted by 29 May. The contract was due to start on 25 June and end by Friday 14 September. However, the detailed advert expresses the hope that they would “receive a draft report in mid-August”. All this leaves very little time for the DfE to respond to the consultation within the twelve weeks recommended in point J of the government’s own Consultation Principles. It will be very surprising if that target is met!

What can I do?

Whilst it’s tempting to think that August provides a welcome respite from contacting our MPs, the HE community needs to hit the road running at the start of September. We cannot rely on the flurry of Petitions to Parliament presented in the final weeks before the parliamentary recess. These have doubtless alerted some MPs to our concerns about the way the consultation was conducted, but we also need to convince as many of them as possible that the DfE’s overall direction of travel regarding EHE is unhelpful and unnecessary. If they are to take up our cause with Damien Hinds, then they need to be meeting with their HE constituents from the start of September.

Parliament next sits on 4 Sept, then adjourns on 13 Sept for a three week Conference Season. All MPs, especially Liberal Democrats ones, need to be well briefed by then so that if EHE features on their conference agenda, they are motivated to speak up on our behalf.