When Data Doesn't Come: Escalation & the Force of Hierarchy
You have shared the template. You have walked the sustainability team through it. You have had a separate call with HR and another with operations. You have sent follow-up emails. And yet, the data is not coming.
This is not the exception. This is the rule. Data collection is the number one reason ESG reporting engagements take longer than planned. Not the writing. Not the frameworks. Not the design. Getting data out of people is the single hardest part of the entire process.
Understanding why it does not come (and having a systematic approach to getting it when it does not) is what separates an experienced consultant from someone who just sends polite reminder emails until the deadline passes.
Data collection is the bottleneck. Not frameworks. Not writing. Not design. Getting data out of people is the hardest part of the entire ESG reporting process. If you accept this upfront, you can plan for it instead of being blindsided by it.
Why Data Doesn't Come
Before you can fix the problem, you need to understand the root causes. In most engagements, data stalls for one or more of these reasons:
1. It is not their priority. The HR manager has hiring targets, attrition issues, compliance deadlines, and employee grievances to handle. Your sustainability data request is, at best, item number 15 on their to-do list. They are not ignoring you out of malice: they are ignoring you because they have more pressing work.
2. They do not have it in the format you need. They might know intuitively that "we train our people a lot," but converting that into GRI 404-1 compliant training hours per employee by category and gender requires them to query systems they rarely touch, or worse, manually compile data from paper records.
3. They do not understand what you are asking. Despite your walkthrough calls, some data requests remain unclear to the people who need to provide them. "Total energy consumption by source" means something different to you (a structured table in GJ by fuel type) than to a facilities manager (a stack of electricity bills).
4. They do not want to share. This is rarer but real. Some departments are protective of their data. Maybe the numbers are not flattering. Maybe they are worried about how the data will be used or interpreted. Maybe there is a political dynamic within the organization that you are not aware of.
5. Nobody told them it was important. The sustainability team asked, but the department does not report to the sustainability team. Without a mandate from someone in the chain of command, the request has no teeth.
Level 1: Explain the Need
Your first approach should always be education, not escalation. Most people cooperate when they understand why something matters.
This means going beyond "we need this for the report" and explaining:
- Who will see this data. "This will be published in the sustainability report that goes to investors, rating agencies, and the board of directors."
- What happens if it is missing. "If we cannot report training data, the GRI Content Index will show a gap, and rating agencies like MSCI will score us lower on human capital development."
- How it benefits their department. "Reporting health and safety data properly can actually showcase the work your team has been doing. This is your chance to highlight your safety record to senior leadership."
Be specific. Be patient. And be genuinely helpful: offer to sit with them and help extract the data from their systems if needed. Sometimes the barrier is not willingness but capability.
Getting data from reluctant departments is like getting a child to eat vegetables. You can explain why it is good for them (Level 1), you can make it easier by cutting it up and mixing it into something they like (helping them extract data), or you can eventually call in a parent who says "eat your vegetables" (hierarchy). The sequence matters: you do not start with the parent.
Level 2: The Force of Hierarchy
When explanation and assistance do not work (and sometimes they will not), you need to escalate. This is not a failure. This is a standard part of the process.
The force of hierarchy means getting someone senior enough in the organization to mandate the data collection. In practice, this usually means:
- Raising the issue with your primary contact (the sustainability team lead)
- Having them escalate to their manager or the C-suite sponsor of the sustainability report
- The senior leader sends a direct communication to the relevant department head, making the data request a formal ask with a deadline
This works because organizational incentives are hierarchical. A department head who can safely ignore a request from the sustainability team cannot ignore a request from the CFO or the CEO.
How to escalate without burning bridges:
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Frame it as a timeline issue, not a people issue. "We are at risk of missing the report deadline because environmental data from Site B has not arrived. Can you help us get the right person engaged?" This puts the focus on the project, not on blaming individuals.
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Be specific about what is missing. "We need energy consumption data from Site B for FY2024 and FY2025, broken down by electricity, diesel, and natural gas" is much more actionable than "we are still waiting for environmental data."
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Propose a solution. "If the facilities team can share their monthly utility bills, we can do the compilation ourselves." Offering to do the heavy lifting reduces the ask for the other team.
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Document everything. This brings us to a crucial defensive practice: maintain a clear email trail showing when you requested data, what you requested, and what responses you received. This protects you when someone later claims they were never asked.
Example: The escalation conversation
You have been waiting three weeks for water consumption data from the operations team. Here is how the escalation email to your sustainability team contact might read:
"Hi [Name], quick update on data collection status. We have received economic and social data on schedule, but environmental data from operations (specifically water withdrawal and discharge volumes for FY2023-2025) has been pending since [date]. I have followed up twice with [operations contact] but have not received a response. Could you help escalate this with [VP Operations]? If the operations team can share their water bills or meter readings, we can handle the compilation. We need this by [date] to stay on track for the draft deadline."
Notice: no blame, specific ask, proposed solution, clear deadline.
Level 3: Reducing the Ask
Sometimes escalation helps but the data still does not come because it genuinely does not exist in the form you need. In these cases, you need to get creative about reducing the scope of the ask.
- Accept estimates with clear labeling. If the company cannot provide exact training hours, accept a reasonable estimate and note it as estimated in the report. A disclosed estimate is better than a gap.
- Use proxy data. If water data is not available from meters, can you estimate from water bills? If diesel consumption is not tracked, can you use purchase records?
- Narrow the scope. If data from all 20 sites is not feasible, can you report data from the 5 largest sites that cover 80% of operations and note the boundary?
- Flag it as a gap honestly. Sometimes the right answer is to disclose that data is not available and commit to reporting it in the next cycle. This is far better than making up numbers.
There is a hierarchy of data quality in ESG reporting: actual measured data is best, calculated estimates are acceptable, reasonable proxies are a last resort, and gaps should be disclosed transparently. What is never acceptable is fabricating data or reporting zero when you simply do not know.
Managing Your Own Frustration
Here is the part that nobody puts in a framework document: data collection is emotionally draining. You will send the same email four times. You will explain the same template on three separate calls. You will get data that is clearly wrong and have to ask for it again. You will hear "we will send it by Friday" and not receive anything until the following Wednesday.
This is normal. Every consultant who has done ESG reporting has lived through this. The trick is to not take it personally and to maintain professional persistence without becoming annoying.
A few practical strategies:
- Set a regular follow-up cadence. A weekly status update email listing pending items keeps pressure on without being aggressive.
- Create a shared tracker. A simple spreadsheet showing which data has been received, which is pending, and which is overdue (shared with the sustainability team) creates visibility and accountability.
- Celebrate progress. When a department delivers data on time, acknowledge it. This encourages cooperation and sets a positive example for other departments.
The Two Stakeholder Types to Watch For
Over enough engagements, you will encounter two specific types of stakeholders that make data collection especially difficult:
𦀠The "Wrong-on": someone who does not understand the work but constantly provides feedback as if they do. Their comments are either generic ("make it better") or extremely minor ("fix this comma"). They want everything reviewed repeatedly, they want to schedule calls for every small issue, and their feedback is high noise with low signal. The strategy: acknowledge their input, extract anything genuinely useful, and keep the engagement moving. Do not let them become a bottleneck.
π³οΈ The "Bog-on": someone who provides nothing during the process but blames you when the work is not complete. They will claim they gave you everything (they did not) or deny they were ever asked (they were). The defense: keep a meticulous trail of emails, messages, and meeting notes showing that you repeatedly requested data and provided clear deadlines. Documentation is your insurance policy.
In some organizations (particularly family-run businesses or companies with flat hierarchies), formal escalation can feel culturally inappropriate. In these cases:
- Use peer pressure instead of hierarchy. Show the department that all other departments have submitted their data. Nobody wants to be the only holdout.
- Involve the sustainability team in joint calls with the department. Sometimes people respond better to a request from a colleague than from an external consultant.
- Reframe the request as helping the company achieve its stated goals. "The CEO mentioned wanting the report ready by Q3. This data point is on the critical path."
- In extreme cases, work with whatever data you can get, note the gaps clearly in the draft, and let the draft itself create urgency. When the CEO reads a sustainability report with five "data not available" notations in the environmental section, the data tends to appear quickly.
The reality of ESG data collection is that it is fundamentally a people management exercise. The technical aspects (what metrics to collect, what units to use, how to calculate emissions) are straightforward. The hard part is convincing busy people in busy organizations to prioritize something that is new to them and outside their usual workflow. Master this, and the rest of the reporting process becomes dramatically smoother.
Key Takeaways
- 1Data collection - not frameworks or writing - is the single biggest bottleneck in ESG reporting engagements. Plan for it from day one.
- 2Escalate in sequence: first explain the need and offer to help, then use hierarchy (a senior mandate) when explanation fails, and reduce the ask as a last resort.
- 3Frame escalation as a timeline issue, not a people issue - be specific about what is missing, propose a solution, and document every request.
- 4Accept estimates or proxies when perfect data is unavailable, but label them transparently. A disclosed gap is always better than fabricated data.
- 5Maintain a meticulous email and meeting trail to protect yourself from stakeholders who provide nothing but assign blame later.