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Research aims and methodology

The aim of the evaluation was to assess the effectiveness of the children missing education (CME) database pilot and identify lessons to inform a possible roll out of the database arrangements across Wales in the future. 

The Welsh Government consulted on draft regulations in early 2020 which proposed the introduction of a requirement for every local authority to establish a database of all children of compulsory school age in their area, which could be populated by information received from independent schools and local health boards. The Welsh Government later revised its proposals for the regulations and proposed, via the Children Act 2004 Children Missing Education Database (Wales) Regulations, that local authorities establish a database of children who are potentially missing education.

In September 2024, the Cabinet Secretary for Education Lynne Neagle MS/AS provided a written statement to confirm the decision to progress with the plans consulted upon. It was announced that the database arrangements would be piloted across a small number of local authorities during the first year of implementation. The statement also announced that an evaluation of the pilot would be commissioned (Welsh Parliament). Later that month, the Cabinet Secretary confirmed that the pilot would last for one year (Welsh Parliament) and named the local authorities participating in the pilot.

Section 29 of the Children Act 2004 (UK legislation) which was brought into force on March 10, 2025, via The Children Act 2004 (Commencement No. 10) (Wales) Order 2025, provides for the establishment and operation of databases for the purpose of arrangements under section 25 or 28 of the Children Act 2004 or under section 175 of the Education Act 2002. The Children Act 2004 (Children Missing Education Database) (Pilot) (Wales) Regulations 2025 came into force on 8 April 2025 to apply until 8 April 2026.

The regulations placed a duty on local health boards and General Medical Services (GMS) contractors to disclose 3 pieces of information about children usually resident in the 7 pilot local authority areas by 20 May 2025. These were the child’s name, the child’s address and postcode and the child’s date of birth. 

The Education (Information about Children in Independent Schools) (Pilot) (Wales) Regulations 2025 (UK legislation) came into force on 8 April 2025 and ceased to have effect on 20 May 2025. They required independent schools to disclose information about registered children to the relevant local authority involved in the piloting of the CME database. Independent schools were required to share the same 3 pieces of data with the relevant local authority as required for local health boards and GMS (i.e. the child’s name, address including postcode, and date of birth). They were required to disclose the information by 20 May 2025. 

The work programme for this evaluation was conducted across 4 stages.

  1. An inception stage which included an inception meeting.
  2. Stage 2 involved a desk-based review of documentation and scoping interviews with Welsh Government officials and a representative from the NHS Shared Services Partnership (NWSSP). These tasks informed the development of a theory of change and logic model for the pilot project.
  3. Stage 3 involved fieldwork with the 7 local authorities involved in the pilot project and a sample of 6 independent schools.
  4. Stage 4 involved analysis of fieldwork data and preparation of a report.

Main findings

In terms of the effectiveness of pilot local authorities’ existing systems and processes for determining potential CME, the evaluation found that:

  • around half of the pilot local authorities believed they had strong systems and processes for identifying CME when they got involved with the pilot, whilst the other half thought that they were in a weaker position
  • at the time of our fieldwork, progress was being made by pilot local authorities to adopt more consistent approaches, strengthen collaboration and introduce more formal arrangements with services that could report cases of CME. Less progress was being made to improve information systems
  • most pilot local authorities had systems to monitor pupil transition, such as from Year 6 to Year 7, but the consistency and automation of these processes varied. Monitoring of earlier transitions, such as from nursery to reception was more varied
  • tracking pupils who move between local authority areas is challenging and data-sharing between authorities is often slow and inconsistent. Differences in how schools record pupil destinations add further complications and local authority staff often have to follow these up manually
  • all pilot local authorities reported having policies that prevent schools from deregistering pupils without explicit authorisation from the local authority. Good practice included requiring schools to confirm a pupil’s educational destination before removing them from roll
  • all local authorities had a CME register in place prior to the pilot, but systems varied from advanced integrated databases to basic spreadsheets, and their effectiveness in tracking CME varied
  • approaches to recording families providing unsuitable EHE as well as recording how long a child had been missing education were inconsistent 
  • arrangements for sharing information about pupil movements to and from the independent school sector prior to the pilot were limited, inconsistent and mostly informal. Where arrangements worked well, they relied on local relationships rather than formal data-sharing agreements 
  • independent schools who contributed to the evaluation did not previously share information with local authorities about children enrolled at their setting or when they stopped attending the school. 

In terms of the efficiency and effectiveness of the process of receiving data from the health sector, the evaluation found that: 

  • the process was efficient and the transfer of data from NWSSP to pilot local authorities ran smoothly. In excess of 167,000 records were transferred securely and efficiently to 7 local authorities 
  • issues around the format, quality and accuracy of the NHS data hindered local authorities from matching the data with their own records. The most concerning issue reported by local authorities related to the accuracy of the NHS records 
  • local authorities would have benefited from accessing more information for each health record received, and the use of unique identifiers would have supported more effective automated matching. 

In terms of the efficiency and effectiveness of receiving data from independent schools, the evaluation found that: 

  • the process was inconsistent. Not all schools complied with the regulations or submitted data within the required timeframes 
  • some local authorities were unsure whether they had received data from all relevant schools, as they reported having no access to a single register of independent schools in Wales
  • in some cases, schools did submit data, but it was not sent to the email address provided by the local authority 
  • the quality of data shared by independent schools was mixed. Whilst generally considered up to date, the data sometimes included pupils who were out of scope in terms of age or geographical location 
  • schools submitted data in a variety of formats and with different levels of security. There is a need to improve data transfer processes and replicate good practice observed during the pilot 
  • expanding this exercise across Wales is likely to create challenges, particularly for schools that enrol children from multiple local authority areas. One potential solution would be for schools to submit data once to a central portal, indicating the local authority where each child resides, and for this information to be shared with the relevant authorities
  • some data records shared by independent schools were already known to local authorities, notably pupils maintained by the authority through IDPs and placed in these settings by the authority, raising questions about the usefulness of such data transfers. 

In terms of the number of potential CME found as a result of the CME database pilot, the evaluation found that:

  • receiving data from the health sector proved valuable for identifying potential CME in around half of the pilot local authorities, but less useful in the remaining half
  • the pilot data proved particularly helpful for smaller, rural local authorities with less transient populations, where the task of data matching was more manageable and semi-automated partial matching techniques could be applied effectively. In contrast, larger urban-based authorities with more transient populations, despite having more sophisticated CME processes and MIS, struggled to make full use of the health sector data due to the scale of the data and issues with its quality
  • identifying potential CME was hindered by the lack of information about children attending schools in neighbouring local authority areas. Addressing this gap in data should be a priority for the future, as many potential CME identified via the health sector database were thought to be enrolled in schools outside their home authority
  • tools such as Excel’s Fuzzy LookUp and Power Query proved useful for partial matching of data records and should be more commonly adopted if the pilot were to be extended across Wales.

In terms of comparing the number of CME known before and the potential known after the CME database pilot, the evaluation found that:

  • the pilot led to a substantial increase in the number of potential CME known – over 5,000 across 5 local authorities that provided data, but many of these records related to children who had either moved out of the area or were enrolled at neighbouring local authority schools
  • three local authorities reported that the pilot had helped them improve the quality and reliability of their data, and therefore help identify potential CME cases
  • the ongoing data matching and follow up work at the time of our fieldwork meant that other authorities were unable to determine whether the pilot had helped them identify previously unknown potential CME cases 
  • local authorities’ ability, readiness, and capacity to follow up on their remaining unmatched records varied. Follow-up activity was dependent in some cases on accessing data from neighbouring local authorities and all independent schools in the first instance. Other local authorities were reluctant to pursue follow-up due to concerns about the quality and currency of the NHS data and because of the large-scale nature of the work. 

In terms of amendments needed to the regulations or the process of receiving data, the evaluation concluded that the pilot has been a worthwhile exercise in principle, if not yet in practice, because it has encouraged improvements to local authorities’ processes and practices and provided reassurance and validation for some local authorities that their existing systems were robust. 

Expanding the pilot in its current form would not be an effective use of resources due to the need to ensure consistency and use of existing CME processes across pilot local authorities so that they operate in line with existing statutory requirements and ongoing data quality issues with health sector records. Collectively addressing these two issues should be the next priority, rather than asking local authorities to repeat the exercise or extend it to additional areas. Once these issues have been resolved, a wider roll-out of the health data-sharing pilot could then be considered.

Recommendations

A series of recommendations are offered for consideration. Whilst many of these are focused upon pilot local authorities, they should be considered as broader recommendations for future implementation.

Recommendation 1

Pilot local authorities should continue to address areas of weaknesses identified within their existing CME processes, with ongoing support from the Welsh Government and by learning from good practice in other areas, in order to comply with the national guidance.

Recommendation 2

The Welsh Government should provide advice and guidance to local authorities to ensure that responsibility for CME is not placed on education welfare services alone, and that all relevant departments, including admissions and ALN teams, are fully aware of their responsibilities. Similarly, local authorities should be supported to ensure that other front-line agencies such as health, police, youth offending and leisure services are aware of their responsibilities in terms of identifying and referring potential CME to local authorities.

Recommendation 3

Pilot local authorities should improve the consistency and automation of the systems used to monitor pupil transition, particularly from year 6 to 7 and from nursery to primary school settings.

Recommendation 4

Pilot local authorities should require schools to complete the destination field in their MIS before a pupil is taken off the roll. Schools should not be allowed to remove a pupil from roll until a confirmed next destination has been verified.

Recommendation 5

Pilot local authorities should record how long each child has been out of school on their CME registers to help monitor and respond to cases more effectively.

Recommendation 6

Cross-border data-sharing protocols between local authorities should be strengthened and formalised as a matter of priority, particularly for pupils who never enrolled at a school in their host local authority area.

Recommendation 7

The Welsh Government should issue a reminder to all local authorities on how to record EHE learners when the education provided is considered unsuitable. Local authorities should adhere to Welsh Government guidance on recording of this information and any follow up action taken.

Recommendation 8

The Welsh Government should explore the introduction of data-sharing agreements between local authorities and the independent school sector – or consider making this a statutory requirement. This would ensure that independent schools share information with local authorities about all pupils on their roll at the start of the academic year and notify local authorities promptly when a pupil leaves their roll.

Recommendation 9

Pilot local authorities and the independent school sector should reflect on the lessons learned from the pilot about how data is shared between independent schools and local authorities (see section 8.3 of the report for details). In particular, consider whether a centrally coordinated approach would make these arrangements more effective.

Recommendation 10

The Welsh Government should provide clearer guidance for independent schools about which boarding pupils to include in their data returns, for example, whether to include those boarding within the host authority area or those whose usual home address is within that area.

Recommendations offered in the event that the health sector data requirements be replicated or rolled out in the future

Recommendation 11

Pilot local authorities should share information with NWSSP about children they have identified as no longer attending their schools and no longer showing as active on their LA databases to allow the NHS Wales to update their records.

Recommendation 12

If the health data transfer pilot is repeated or extended, NHS Wales should consider including additional data fields within the records shared with local authorities in order to support more accurate matching with local authority datasets. Ideally, data records should include UPRN data, and, where possible, parents’ names. Local authorities who do not currently hold UPRN data should explore its adoption.

Recommendations offered in the event that the independent schools data requirements be replicated or rolled out in the future

Recommendation 13

The Welsh Government should exclude pupils already maintained by local authorities who are placed in independent schools due to their ALN from any future data-sharing exercises, as these records are already held by local authorities.

Recommendation 14

The Welsh Government should provide clearer guidance to independent schools about the data they need to provide and what should be excluded. This should include a reporting template and clear instructions on the expected format of the data. Local authorities should also make a secure portal available for schools to submit the data securely.

Recommendation 15

The Welsh Government should share a database of all independent schools in Wales with contact details (name and email address) to local authorities to help them monitor responses and ensure that datasets are complete.

Recommendation 16

Consideration should be given to the development of a central portal where independent schools can submit their data once, simplifying reporting and communication. Local authorities should explore how such a central portal could be established and managed.

Recommendations offered in the event that the health sector data requirements be replicated or rolled out in the future

Recommendation 17

Local authorities should automatically inform the child’s residing local authority when a pupil enrols in a school in their area. Addressing this gap would make future health sector data more useful and easier to match, helping authorities identify potential CME more effectively.

Recommendation 18

Pilot local authorities should share experiences and techniques for automated and semi-automated data matching, including tools such as Excel Fuzzy LookUp and Power Query. This would support more efficient and consistent matching processes, particularly if the pilot is expanded across Wales.

Contact details

Report author: Nia Bryer and Heledd Bebb, OB3 Research

Views expressed in this report are those of the researchers and not necessarily those of the Welsh Government.

For further information please contact:

Schools Research Branch
Social Research and Information Division
Knowledge and Analytical Services
Welsh Government
Cathays Park
Cardiff
CF10 3NQ

Email: SchoolsResearch@gov.wales

Social research number: 56/2026
Digital ISBN: 978-1-83745-362-7

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