Memorandum by Document Technology Ltd
(POS 21)
1. Executive Summary
We shall show our past experience and the perceived
position for the CEPE 2004, which is entirely different from the
administration point of view. The CEPE is far more complex than
any previous pilot election, yet the ability to tackle the task
is being assumed based on previous pilot performance.
1.1 The process of issue of the ballot papers
has been fundamentally changed for the CEPE by the requirement
of a signed security statement and a separate ballot paper envelope.
This means that new techniques are being piloted whereas the intention
was to merely test scaling up.
1.2 The scaling up to regional electoral
area places a management responsibility on the RRO which he has
previously not had. The RRO needs powers of direction and will
probably be obliged to run the operation from the centre—certainly
much more than in a non-pilot region.
1.3 The operating problems of the CEPE include
the large scale secure storage of completed ballot papers until
"posting day"—the Royal Mail cannot under its
rules accept first class mail for holding until a designated posting
day. This then means that Royal Mail will have to collect around
15 million items in one day and deliver 95% of them the next morning.
1.4 The risks for RRO's and producers has
risen to regional electorate size. The slim risk of a re-run of
an entire region will need to be insured by all parties involved.
There are at present problems with defining limits of liability
of the producer on handover to the Royal Mail and there is some
reluctance to insure producers who are not supplying the entire
region for which cover is being given. The best solution, suggested
by our underwriters, is for a single catch all indemnity policy
which covers all involved parties, including the RRO for the ultimate
risk.
1.5 The potential break of the audit trail
of ballot papers issued when they are handed over to Royal Mail
is a major weakness in any all postal ballot.
1.6 The CEPE is more complex than previous
pilots, yet the timetable is already behind that of 2003. No one
knows who is to pilot, what the ballot paper sizes are, what the
election timetable will be, nor when suppliers may be able to
place orders for stationery. No supplier has been asked about
capacity and there is some doubt that there is sufficient capacity
to handle all four proposed pilots with a degree of safety. The
time is rapidly arriving when suppliers will say "too late"
and walk away from the ever increasing risk.
1.7 Control of the returned ballot papers,
particularly in combined elections needs to be automated, using
individual barcodes for each document, so that the matching can
be done by software, not mark one eyeball. This in turn dictates
the systems which can be used for issue—none of this has
been discussed with potential suppliers
DETAILED SUBMISSION
2. Process
2002-03
All 6 pilots undertaken by DTL were with no
declaration of identity. This required an outgoing envelope, an
address flyer attached to a ballot paper and a return envelope.
A computer based recording system was used in 4 cases in 2003,
using barcodes on the reverse of the ballot papers. Where this
was done as returned ballot papers were received, "marked
registers" were made available to political parties. All
6 were judged a success and there were no operational problems
in any pilot. There was a team approach by DTL and its clients.
Suppliers were involved at an early stage and their input was
vital to the success of the projects.
2004
The requirement of a security statement and
a ballot paper envelope, together with an uncertain size of ballot
paper for both European and full council elections has made the
forward planning for suppliers almost impossible. There has been
no contact with suppliers to ensure that proposals are feasible
or even if there is sufficient capacity in the UK. Entirely different
systems will need to be operated by suppliers and the election
staff. By this time last year suppliers were in a position to
begin ordering stock and to book production slots—further
delays create more risk to an already tight timetable.
3. Effect of Scaling Up
2002-03
The small electoral areas of wards limited both
organisation and risk to small units. Management was split into
wards and then merged into local authority units. Most staff were
experienced in local elections.
2004
The EPE regions in the pilot areas range from
1.8 to 5.2 million voters. The Management of these vast areas
cannot be left to a "consortium" approach—it has
to be driven from the centre else chaos will ensue. Many staff
are inexperienced in EP elections. The increased risks are dealt
with separately.
4. Extended Timetable
2002-03
Without the extended timetable, which provided
an extra 7 days in which to prepare and post out the ballot papers
these pilots would have struggled to meet posting deadlines.
2004
There is at present no extension of the timetable
and anything less than a full 7 days advancement will severely
restrict suppliers' capacity to meet 3 times the volume of the
2003 pilots.
5. Suppliers Production Methods
2002-03
Ballot papers were watermarked as they were
printed with candidate names. The issue process was smooth, all
enveloping and mailing was done under the surveillance of a representative
of the council concerned. Procedures were developed for the reprinting
and enveloping of damaged ballot papers. All items were presented
to the Royal Mail in a Walksort pattern gaining the 36% discount.
2004
The sheer size of handling even just one region
requires facilities hitherto not envisaged. The prospect of storing
several million envelopes containing ballot papers for up to two
weeks before Royal Mail can collect them requires extra high security
warehouse space of more than 5000 sq ft. The empty envelopes required
fill several large delivery containers. The personalising equipment
needed is quite different and highly specialised, with little
potential for future use except in other postal ballots.
6. Risks and Their Insurance
2002-03
With the small size of each electoral area,
the ultimate risk of re-running a by-election due to a successful
petition was small enough to be covered by suppliers' or RO's
insurance or sinking funds. The Dudley case has shown what might
happen and all future pilots must be fully insured by all who
have an insurable interest to avoid cross claims against an uninsured
party.
2004
With the much larger electoral areas of the
EPE, the risks of a re-run are scaled up to the entire electorate
of a region—up to 5.2 million voters. Whilst this risk may
be very small, no competent supplier will get involved without
adequate cover for his exposure. The RRO is charged with ensuring
that the election is successful, which we interpret as ensuring
that every risk is insured, even if he does not directly insure.
The issue of ballot papers is now broken down into risk phases.
6.1 Phase 1
The compilation of the data from the electoral
registers in a form agreed with the "producer". The
risk to avoid is disenfranchisement by non issue of a ballot paper.
The supplier is given control totals and can effect a reconciliation
before printing.
6.2 Phase 2
From the agreed data, the producer produces
numbered ballot papers, security statements and ballot paper envelopes.
These are merged together with a reply envelope, an instructions
sheet and inserted into a mailing envelope. The ballot paper "packs"
must contain documents which are matched for the voter. The supplier
must guarantee a 100% perfect match. To meet the demands of economy,
the ballot paper mailing will be presented to the Royal Mail in
a Walksort pattern, which earns 36% discount. Throughout the entire
process an audit trail runs to ensure that every data record results
in a mailed ballot paper pack. The producer has a liability until
there is no claim for incorrect contents of the ballot paper packs,
but his liability for 100% mailing should cease upon handover
to Royal Mail, and there should be controls in place.
Clearly the risk in phase 2 is that of the supplier,
and this applies to any council which is permitted to produce
and mail its own ballot paper packs.
Initial negotiations with brokers and underwriters
indicate that there is a reluctance to directly insure a supplier
where he is not acting as sole supplier for the entire area for
which the risk is being insured. This could have a significant
impact on the way that contracts can be awarded for supply in
the CEPE. Proposed "local contracts" like those of last
year might not be possible. Our underwriter has suggested that
there should be a single catch all indemnity insurance in which
all suppliers and the RRO are covered. This would ensure that
there is no double insurance but would permit smaller suppliers
to enter local contracts. This matter needs the urgent attention
of the RRO's and the relevant government departments.
6.3 The Interface Phase 2/Phase 3
The interface between the producer and the Royal
Mail is very unsatisfactory, and could lead to disenfranchisement
claims being "passed on" to innocent producers.
2002-03
The items were presented to Royal Mail with
the usual listings and dockets. The signature on the docket merely
confirms that the Royal Mail will charge for the number of items
specified and the completeness of the mailing is assumed by Royal
Mail, but no responsibility is assumed by Royal Mail for completeness.
This means that if Royal Mail loses some items it can claim that
the mailing received was incomplete, and no check was made at
the point of handover (other than to sample items for the weight
claimed).
This interface is the subject of much concern,
and we are being advised to produce a comprehensive listing of
the contents of each mailbag, to be handed to the Royal Mail with
an invitation to agree the contents, and to disclaim any bag not
so checked at the point of handover. The point at issue is that
all through phases 1 and 2 an audit trail maintains control of
the number of ballot paper envelopes issued, only to be lost when
they reach Royal Mail. In any claim of disenfranchisement this
"fuzzy" interface could allow Royal Mail to avoid liability
even if the items were lost whilst in their care. Again underwriter's
advice is to include Royal Mail in the catch all indemnity.
6.4 Phase 3
Royal Mail delivers—but there is no guarantee
of delivery, and no audit trail. Unless the interface rules are
clear there is no point at which the producer's liability for
numeric correctness ends and the Royal Mail's starts.
6.5 Phase 4
The receipt, recording and matching of returned
ballot papers and security statements, the verification and the
count are clearly an insurable risk of the RRO.
7. Supplier Insurance
No competent supplier is going to undertake
this work without adequate insurance cover. If he is forced to
insure directly the underwriters may require a single supply contract
for the total area of their risk. There can then only be one supplier
for each region. This places great pressure on those suppliers
who might be able to meet the demand, and eliminates many smaller
suppliers. All potential suppliers will need to demonstrate that
they can establish a clear cut interface with Royal Mail. We do
wish to make the strongest case for a single indemnity covering
all parties.
8. Timing
2002-03
Because the suppliers were part of the teams
from an early stage it was possible to place orders for stationery
in good time and last minute rushes were avoided. This early involvement
allowed the suppliers to contribute their experience to the design
of the systems used. The entire issue process was a well oiled
machine. Costly errors were avoided.
2004
There seems to be no understanding of the urgent
need for suppliers to be ordering base stationery and production
space. We are already past the point where we can choose what
equipment we might need—we now have to have a short notice
procurement program, which will not produce the best systems or
results. The requirement for envelopes is now pressing—45
million are not made in a few days. There is still no certainty
about the size of the ballot papers, the election timetable or
when the order will be signed. In addition there is still uncertainty
as to which regions will be all postal pilots. This is a disaster
waiting to happen. There will come a point in time when suppliers
will say "too late" and just walk away from the problem—this
may be sooner than is imagined.
9. Control of Returned Ballot Papers
2002-03
We have always provided a computer based system
for barcode capture of the ballot paper number to provide a permanent
verification record and total, marked registers and a system for
voiding and replacing lost ballot papers. The 2003 pilots in Blyth,
Stevenage and St. Helens all used the system to great effect.
All produced turnout figures at regular intervals—one on
its website 3 times a day.
2004
With the more complex election there is a need
to enhance the numbering and barcoding of the matched items so
that the barcode capture can be automated to ensure that there
is sufficient time to complete this process before the count.
This requires a complete rethink on how the ballot papers are
returned and processed. The requirement for individual barcode
numbers for each ballot paper and the security statement means
that registration software used in previous years will just not
be able to handle the barcode capture. If there is no computer
based system which can effectively match two ballot paper barcodes
to a security statement barcode then the only alternative is a
manual system—not a practical proposition in our view.
9.1 Unsigned Declaration/Security Statements
2003
Two councils returned large numbers of unsigned
declarations of identity, but retained the ballot papers pending
return of the signed declaration. The declaration quite clearly
states "I am the person to whom ballot paper number £££££
was sent." In order for that to be signed truthfully, the
voter needed to check the number on the ballot paper, but this
had not been returned. We challenge the correctness of this procedure.
2004
Based on last year's experience there is a proposal
that all unsigned security statements are returned without the
ballot papers for signature and return. Quite apart from whether
this is legally correct, from an administration point of view
it will lead to large numbers of mismatched ballot papers. We
are not sure that the RRO has a duty to return unsigned statements,
but if he does then he also may have a duty to chase up those
which are not returned within say four days, and so on. The RRO
has more than enough work to do at this time and he can well do
without having to wet-nurse voters who cannot understand simple
instructions.
10. Supplier Costs
Until there is more certainty about the details
of how the CEPE pilots will be run any cost comparison with 2002-03
is meaningless. What will drive costs upward is the fast diminishing
lead time for suppliers to set up supply lines for base stationery
and printing.
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