Memorandum by the Association of Electoral
Administrators (AEA) (VOT 13)
1. INTRODUCTION
The Association of Electoral Administrators
was founded in 1987 and is the professional body representing
the interests of electoral administrators in the United Kingdom.
Its objectives include the offering of advice in connection with
the organisation, administration and oversight of elections, electoral
registration and any related activities within or outside of the
United Kingdom. The Association has over 1,300 members in the
UK who have been at the forefront of implementing change in election
and electoral registration during the last few years.
2. EXECUTIVE
SUMMARY
The Association is committed to making registration
as easy as possible for electors to ensure that all who want to
participate in the electoral system have the opportunity to do
so. It believes that accessibility and security have to be balanced
so that the latter is not compromised by making the system more
accessible.
There is concern that the introduction of individual
registration could lead to a significant number of potential electors
being omitted from the register without substantial resources
being dedicated to tracing everyone eligible. Although it has
been suggested that household registration could continue but
with each individual elector signing the registration form, it
is considered that this is too complicated and could lead to unacceptable
delays in the form being returned. If individual registration
is to be pursued, there must be safeguards for those:
— for whom English is not their first
language;
— for those in care homes;
— for those at institutes of higher
learning; and
— for those with learning difficulties.
If individual registration is to be introduced,
there will have to be identifiers included, and the National Insurance
number appears to be the most appropriate. The National Identity
Card scheme will take too many years to introduce, and it is important
to initiate individual registration as early as practicable if
electronic/internet voting is to be available in the near future.
There is a fundamental question as to whether
registration should be compulsory or voluntary. There are currently
a considerable number of individuals who have no interest in the
electoral process, and never want to vote. The resources expended
in persuading these individuals to register are out of all proportion
to the benefits of including in the register for a service they
have no desire to use. Although there are some prosecutions for
the non-provision of information to the Electoral Registration
Officer, it would be far too time-consuming for this to be undertaken
on a much larger basis, and it does not have any perceived effect
on others.
In a number of countries, registers are compiled
specifically for each election. This ensures that it is up to
date and that those who wish to vote are able to do so. Such a
system would represent a fundamental change to the current practice,
and is unlikely to find favour with the Government which has expressed
its opposition to introducing consistent timetables for UK elections.
The current system of the register being locally
maintained should be retained as it gives the elector a definable
access point to which they are able to apply to be registered.
There could be a case for a change in legislation to require all
electors who change address to report, in person, by post or electronically
to the relevant local authority to ensure that they register for
services including electoral registration. The locally compiled
register could then feed into a nationally maintained electronic
register.
If electronic registration systems are to be
introduced, there needs to be:
— Independent methods of verifying
the accuracy of the data input as it could be too easy for the
system to be corrupted.
— A choice of methods for those who
do not have access to internet or telephone connections.
— An audit trail to ensure that all
variations can be traced.
The Association has long been concerned with
the requirement to sell the register to commercial interests.
The income derived from such sales is minimal, but more importantly,
the electorate should be asked to provide their details solely
for electoral purposes. This is especially important as they are
statutorily required to provide the information. The register
should be open for public inspection at the office of the Electoral
Registration Officer, and available to political parties, candidates
and elected members only.
One area of particular interest is the question
of franchise. Currently, the franchise is restricted in the following
categories:
| E | Peer of the Realm living overseas. Entitled to vote in European Parliamentary Elections.
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| F | British Citizen living abroad. Entitled to vote in Parliamentary and European Parliamentary elections.
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| G | European Union Citizen, other than British or Irish. Entitled to vote in Local Government elections.
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| K | European Union Citizen, other than British or Irish. Entitled to vote in Local Government and (by choice) European Parliamentary elections.
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| L | Peer of the Realm. Entitled to vote in Local Government and European Parliamentary elections.
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It is questionable whether there should be so many different
categories. In the meantime, there are other foreign nationals
who have lived in the UK for many years who are not permitted
the right to vote despite paying taxes at both national and local
level.
3. SPECIFIC COMMENTS
(a) Advantages of individual registration compared with
existing system of household registration
It is difficult to quantify advantages unless the data supplied
is required for other purposes incidental to voting, ie personal
information, such as identification features, nationality, date
of birth and signature for the purposes of detection of fraud.
Individual signatures would, however, provide a mechanism for
the Returning Officer to check postal vote application forms and
the authenticity of the Declaration of Identity at voting stages.
It would provide a far more accurate register if it was possible
to achieve a high percentage return. It may encourage individuals
to take an active part in the democratic process by completing
a form that might then lead them to exercise their vote!
There are far more administrative disadvantages, such as
increased costs of collecting returns, delays in response and
a subsequent reduced electorate. The existing system provides
for one person in the household supplying the details. Whilst
the process is quite straightforward it does place a responsibility
on the person completing the form to certify information that
he or she might not be fully aware as to the accuracy of—particularly
"opt out." Delays in completing a return is likely to
arise from people temporarily absent from their normal place of
residence, being overseas on duty, in hospital, in institutions
and colleges, from the elderly and from communities containing
large ethnic minority groups. The initial year would provide an
exercise of "dead-wooding" resulting in many names being
removed from the register from non-responders.
(b) Strategies for encouraging registration, in particular
among young voters, and tackling resistance to registration, and
examination of the advantages and disadvantages of compulsory
registration
As every householder is under a statutory duty to supply
the information required on the form this implies that registration
is compulsory. The only exception to this applies to British Citizens
resident overseas, members of Armed Forces and homeless people.
There is little point in having compulsory registration unless
it is properly enforced ideally without having to revert to the
courts. For compulsory registration to be undertaken in a thorough
manner it will be necessary for adequate resources and funding
to be provided to enable a proper door-to-door canvass to be carried
out, and for a common standard being applied throughout the UK.
The "resistance attitude" to registration by the younger
generation and by ethnic minority groups will need to be overcome
and enforcement by law may be a way of achieving this although
the benefits of registration, voting and being involved in democracy
is the real issue and one which needs to be addressed robustly.
Improved and modernised registration methods (by telephone,
email, text messaging etc) may attract young persons. Consideration
should also be given to consolidating the information provided
to Councils. An application for varied purposes ( electoral registration,
council tax, housing, leisure and libraries etc) would reduce
the bureaucracy.
Consideration could be given to making it a condition of
applying (and being granted) a National Identity Card that the
person (if eligible) must be included in the register of electors.
(c) Issues of geographic and ethnic variations in levels
of voter registration
There may be a perception by some that despite being a Commonwealth
or European Citizen the British registration system is for UK
Nationals only and as such others do not register or even recognise
their eligibility.
Employing people from within those ethnic minority groups
and geographical areas to undertake the door-to-door canvassing
work has proved to have a certain amount of success and perhaps
should be encouraged with proper training provided in canvass
techniques and collection of returns. This will however have a
significant resource implications.
(d) Advantages or disadvantages of electronic rather
than paper-based registration systems
Most forms of application are now available electronically.
In time people will expect this to be the main registration method.
Electronic registration can be faster, more efficient and cost
effective.
Automated telephone response systems currently being experimented
with appear to be working reasonably well and is resulting in
reduced costs, time and administrative resources. There is likely
to be, however, concerns about accuracy and whether the system
and data provided remains secure. There may also be issues relating
to data protection and/or human rights over these practices.
(e) Difficulties for the disabled and others unable to
complete forms
Certain categories of people with disabilities, whether
physically or visually handicapped would have difficulty in completing
a return without assistance, regardless of whether it is paper-based
or electronic. A door-to-door canvasser would be able to assist
those people in need of assistance where a family member, social
worker or colleague is not available. Most Electoral Registration
Officers offer a helpline and large print forms and guidance in
Braille. These facilities should overcome individual difficulties.
(f) Availability and confidentiality of the register
Many organisations, the Electoral Commission included, have
called for the Register of Electors to be used for electoral purposes
only.
Since the decision in the Robertson case the knowledge
by electors that this data is provided for commercial and profitable
purposes has led to a negative response by some.
If the Register was compiled for purposes of entitlement
to vote only, and not made available for other statutory purposes,
there would be no need for consideration of having anonymous registration
for specified groups of citizens, and avoid the need to compile
a separate register for re-sale purposes. However, under present
legislation for the sale and use of the register it is desirable
that provision should be made for anonymous registration being
restricted to particular people in certain circumstances or occupation.
Such persons could be registered in pursuance of an annual declaration,
and not being entered on the annual householder/individual form.
They should be entitled to vote by post or proxy only with their
entry being listed at the end of the register under the heading
of "Anonymous or Other Electors". The issue of the marked
copy of the register used at an election should be restricted
to registered political parties on application within a specified
period and to candidates or their election agents for use in connection
with that election. Any list of returned postal voters should
be made available only to registered political parties or candidates
or their election agents on application within a specified period
following the election.
(g) Basis for individual registration eg address-based
or on personal criteria such as NI number or birth date
The principle of using NI numbers might well be seen as an
obvious way forward. How many people do not have a NI number?
Would persons without a NI number be omitted from the system?
Could other Government Departments assist in supplying names and
addresses and other relevant details that may be required for
voting purposes?
Individual registration should be the responsibility of local
Electoral Registration Officers and continue to be address based
and carried out at local level with guidance from the Electoral
Commission. To assist with the compilation of the register, electoral
registration officers should be given power to access information
on an individual as held for statutory purposes by a local authority
or Government Department, including the DVLA and Passport Office.
(h) The desirability of a national electoral register
It is doubtful whether a national electoral register, such
as CORE, will be of much assistance to the maintenance or updating
the electoral register. It may assist in identifying people who
have registered for a change of address without notifying the
electoral registration officer of the previous address. It might
also identify possible duplicate entries, but even that would
necessitate enquiries being made by the electoral registration
officer for confirmation—a time consuming task. There would
still remain the need for the electoral registration officer to
seek application for registration from each individual.
A significant benefit of a national electoral register would
be the platform for e-voting; to enable an elector to record their
vote from outside the area where they are registered for voting.
It would cause concern if the ultimate intention was that electors
could update their entry on line, as this would remove the opportunity
for entries to be questioned as to their accuracy and authenticity.
(i) Means of ensuring the security of the register:
PIN numbers, electoral voting cards, signatures
The essential requirement is to ensure the person who is
registering and indeed voting is that actual person. Appropriate
security mechanisms need to be in place as well as the ability
for the ERO to make security/validation checks. Appropriate "Offences"
with realistic penalties need to be introduced.
PIN numbers are fine in principle as long as adequate and
additional identifiers are in place to validate the users entitlement.
Malcolm Dumper
Association of Electoral Administrators (Executive Director)
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