What Does the Competency Framework Require of Those with Responsibility for Data Management?

What I encounter consistently in my work with trusts on capability development is a pattern around data management that holds across organisations of very different sizes and structures. The data management obligation is understood as a systems question: does the organisation have a platform? Is data being uploaded? Is the record up to date? These are necessary questions. They are not the questions the Estate Management Competency Framework is asking. The framework is asking a different, harder question: does the organisation have the right capability, at the right levels, to take ownership of data management as a strategic function and not just a recording task?

For leadership teams, that distinction matters now more than it has before. The annual return via the MYEE portal from autumn 2026 requires Responsible Bodies to confirm their Standards position. The condition data collection requirement extends the obligation further from 2027. Both depend on data that is accurate, current, and managed with the kind of discipline that the framework specifies at Manager and Strategic levels. An organisation that has the data in the system but does not have the capability to manage it well will not be able to meet those obligations credibly.

What Does the Competency Framework Actually Say About Data Management?

The Estate Management Competency Framework structures data management requirements across all four competency levels: Operative, Supervisor, Manager, and Strategic. Each level carries different responsibilities, and each represents a building block that the next level depends on.

At Operative level, the role is to assist with capturing and obtaining key estate data to inform effective estate management. That is a task: recording information, conducting premises checks, uploading documentation. At Supervisor level, the responsibility expands to supporting accurate recording of data, maintaining accurate registers of property condition, and reviewing and updating data management storage systems. At Manager level, the role shifts substantially: taking ownership of data management processes to capture an accurate picture of the condition of the estate, ensuring records are current, maintained and accessible, developing systems for reporting data to appropriate bodies, and conducting and managing data audit processes. At Strategic level, the requirement is leadership: defining the specifications for data management systems, taking responsibility for data accuracy, and interpreting estate data on condition and sufficiency to reflect strategic objectives.

The progression is explicit. Data management at Strategic level is not an administrative function. It is a leadership function with direct consequences for the organisation's estate strategy and Standards compliance.

Why Does This Matter to a Leadership Team Now?

The MYEE portal and the annual return are the immediate context. But they are not the only reason the capability question has become urgent. The Competency Framework has always specified these requirements. What has changed is that the annual return will make the adequacy of an organisation's data and the credibility of its Standards confirmation visible to the DfE. An organisation with weak data management capability will struggle to produce a credible return, and that is now a consequential problem rather than an internal one.

In the organisations I have supported through assurance preparation, the data management gap presents in a specific way. The operational records are often there: compliance certificates are uploaded, condition checks are completed. What is missing is the management layer. There is no process through which the accuracy of the data is verified. There is no audit discipline. There is no systematic approach to using historical data in forward planning. The Competency Framework identifies these as Manager-level functions. An organisation that does not have someone operating at Manager level in data management is carrying a capability gap that the annual return process will expose.

What Competency Level Does Your Organisation Need in Each Role?

The Competency Framework's four levels map to typical roles in recognisable ways. An operative-level role undertakes data recording tasks: premises walk-arounds, condition checks, uploading documentation. A supervisor-level role manages the accuracy of what operatives record and maintains registers. A manager-level role takes ownership of the data management process, ensures data quality, develops reporting, and manages audits. A strategic-level role defines the data architecture, takes responsibility for accuracy at portfolio level, and connects data management to the estate strategy and asset management plan.

A single-school trust may have only two or three roles covering these functions. A multi-academy trust with a large estate portfolio may need explicit Manager and Strategic-level data capability across multiple people. The assessment question is the same regardless of size: is there someone in the organisation who is operating at Manager level in data management, taking ownership of data processes and accuracy? And is there someone with Strategic-level capability connecting the data picture to the estate strategy?

What I consistently encounter in schools and trusts at this maturity level is that the Manager-level function is either absent or is being performed by someone whose role has not been structured to support it. The data management work gets done at Operative and Supervisor level, and the management and strategic oversight sits nowhere in particular.

How Should a Trust Assess Its Current Data Management Capability?

The assessment process follows the framework directly. Map the data management activities that are currently being performed across the organisation against the four levels. Identify which activities at each level are present, adequately resourced, and clearly owned. Identify which activities are absent or unclear. The gaps at Manager and Strategic level are the ones that are most likely to affect the organisation's annual return position and its ability to manage its data as the condition data collection obligation extends.

The assessment should also test whether the capabilities present at each level are genuinely embedded or are dependent on one individual. In my work with trusts on capability development, single-point-of-failure in data management is a recurring risk. When the person who holds the data management knowledge leaves, the data management discipline goes with them. A trust that has built its data management around one individual rather than around a structured process has not embedded the Competency Framework's requirements: it has accommodated an individual who happens to be covering them.

What Does Good Look Like at Leadership Level?

A leadership team that has its data management capability in order will be able to answer four questions with confidence. Who is responsible for data accuracy in this organisation? What process is in place to verify that estate data is current and correct? How is data being used in forward planning and in the development of the asset management plan? And is the organisation's data infrastructure designed to meet the condition data collection requirements that will be in place from 2027?

If those questions cannot be answered clearly, the capability assessment has identified a gap. The question then is how to address it: through recruitment or role redesign to build the Manager-level function, through training to develop the capability in existing roles, or through an interim external arrangement while a more permanent solution is structured.

The Competency Framework provides the specification. The leadership team's job is to assess honestly whether the organisation meets it, and to take responsibility for the gap if it does not.

Frequently Asked Questions

Does data management in the Competency Framework refer only to condition data?

No. The framework's data management function covers the full range of estate data: condition, compliance, sufficiency, financial, and performance data. Condition data is the most prominent in the current policy context because of the condition data collection requirement from 2027. But the framework's data management requirements are broader, and an organisation that addresses only condition data while leaving gaps in compliance or performance data management is not meeting the framework requirements.

What is the relationship between data management capability and the annual return?

The annual return requires confirmation of the organisation's Standards position. That confirmation is only credible if the evidence that underpins it has been maintained accurately. Data management capability is the operational foundation of a credible return. An organisation that cannot demonstrate how its data is managed, audited, and verified will find it difficult to produce the evidence base the annual return requires.

What training exists to support development at Manager and Strategic levels in data management?

The Competency Framework identifies the skills and knowledge required at each level but does not specify a single training pathway. Organisations developing Manager-level data management capability typically draw on a combination of technical training in estate data systems, professional development in data governance and quality assurance, and structured mentoring or coaching arrangements. The assessment conversation should identify what is needed for each individual, not assume a generic solution.

How should a trust approach this if it is a small single-school organisation?

The scale of the data management function will be smaller in a single school, but the structural requirements are the same. Someone needs to own data accuracy. Someone needs to audit records. Someone needs to use the data to inform planning decisions. In a small organisation, those functions may be carried by one or two people. The important thing is that they are explicitly assigned and supported, not left to accumulate informally.

Julie Lawson leads the People and Capability domain at The Estates Strategy Partnership.