Memorandum by Experian (VOT 17)
1. Experian is a global leader in providing
information solutions to organisations and consumers. It helps
organisations find, develop and manage profitable customer relationships
by providing information, decision-making solutions and processing
services. It empowers consumers to understand, manage and protect
their personal information and assets. Experian works with more
than 50,000 clients across diverse industries, including financial
services, telecommunications, healthcare, insurance, retail and
catalogue, automotive, manufacturing, leisure, utilities, e-commerce,
property and government. Experian is a subsidiary of GUS plc and
has headquarters in Nottingham, UK, and Costa Mesa, California.
Its 12,000 people in 26 countries support clients in more than
60 countries. Annual sales exceed £1.3 billion.
2. The UK credit reference agencies (CRAs)
are registered under Part III of the Consumer Credit Act 1974.
The two major CRAs—of which Experian is the largest—that
process consumer credit information were set up over 30 years
ago to provide databases of personal information for use by businesses.
They act as "trusted third parties", providing data
to a wide range of organisations including the financial services
industry to assist them in making decisions relating to the provision
of credit.
3. Experian Ltd has been purchasing and
maintaining an Electoral Register database since the early 1980's
for use in a wide variety of applications. Since the Implementation
of the Representation of the People Act and the Supplementary
Regulations thereto (ROPA) those uses have been firmly split between
use of the full register as permitted under section 114 and use
of the edited register.
4. Experian processes in the region of 100
million credit searches each year and the electoral register is
a vital part of the decision process for many of our 10,000 credit-granting
clients. The data is overlaid year on year to provide a comprehensive
30+ year record of the residency profile of the adult population
of UK residents that are eligible to vote either in UK or European
elections. This data is a vital tool in the fight against fraud
and money laundering and also for many people provides an important
stability measure used in credit decisioning systems.
5. Experian wishes to comment on just four
of the areas of interest to the Committee:
6. Advantages of Individual Registration
Compared with the Existing System of Household Registration
7. There are both advantages and possible
disadvantages in moving from the current "head of household"
registration to individual registration.
8. Concerns have been raised that it might
result in a reduction in registration rates. There are a number
of ways in which this might be mitigated and this concern should
not be used as a reason for continuing the present system.
9. Quite apart from the legal imperative
to cease accepting information and instructions (to opt out) from
third parties there should be an increase in accuracy if the individuals
concerned complete the forms about themselves.
10. "Head of Household" currently
covers not only a parent or partner but also landlords, many of
which complete the forms without reference to the individuals
concerned. Extreme examples may be seen in the case of university
halls of residence sending in forms covering c1,000 individuals.
They cannot possibly be in a position to check the accuracy of
information supplied in the way that the data subject would. This
will become even more important if more information is sought,
such as date of birth. Neither do such "Heads of Household"
usually actually ask the data subject for their instructions in
respect of the "opt out" of the edited register.
11. Strategies for encouraging registration,
in particular among young voters, and tackling resistance to registration;
and examination of the advantages and disadvantages of compulsory
registration
12. Many people do not register to vote
because they are not permanent residents or are not particularly
interested in voting. They may even believe that use of the register
for checking residence and tracing is much more widespread than
it actually is. Voter registration is likely OT be higher if the
individuals themselves believe there to be an advantage for them
in doing so. Some local authorities have pointed out that the
data is used to assist access to other services such as credit.
Many consider this to have proved to be an incentive.
13. As the uses of the register are somewhat
limited the range of incentives that could be offered may not
appeal to certain sectors, for example those that do not use mainstream
credit or shop on the Internet. However, were it to be a part
of the eligibility checks for other services deemed essential
to them then they too will be incentivised to register too, even
if not for the purpose of voting. For example, checks for benefit
claims could reach a different sector.
14. In order to establish which sectors
are subject to low registration levels, but are using other services,
access to large scale databases covering the population as a whole
could enable a more accurate profile of those people that are
not registering to be built up.
15. Issues of geographic and ethnic
variations in levels of voter registration
16. There are sophisticated profiling models
available that segment the population by postcode (and at household
within postcode) in order that commercial users may understand
the characteristics of the residents. These systems typically
use data from a number of sources such as Census overlaid with
other information. It is used as a proxy for more detailed household
level data and to understand the characteristics of certain groups.
Analysis of this type is valuable in order to understand the features
of the groups that are not registering and indeed, may identify
the preferred communication medium for that sector which would
enable government to encourage their participation in democracy.
17. Advantages or disadvantages of electronic
rather than paper-based registration systems
18. The current annual canvass system has
an in-built security check in that the pre-filled forms are sent
to the address for the current occupier to confirm or amend. This
makes it more difficult for others to intercept the form and fraudulently
register at an address. The same is not true of the rolling register
however and the CRAs have for some time raised concerns about
the facility for individuals to obtain forms on the internet and
register at an address with, apparently little or no authentication
taking place. Furthermore, the rolling register system often results
in two separate households being registered at an address because
the previous occupant is only removed if they, themselves, complete
a rolling register form and their new local authority forwards
it to their old local authority for their record to be removed.
19. There are highly automated personal
identity authentication systems available that use a wide range
of data to verify residence of individuals at an address which
could address these concerns and could be used to facilitate greater
levels of electronic registration without compromising security.
Indeed, use of such systems could improve the reliability and
accuracy of the data and enable removal of movers at an earlier
stage.
20. Use of electronic data capture and a
consistent data format together with a universal data standard
for data checking against another separate data sources could
improve both security and data accuracy by corroborating the electoral
register file with other data.
21. Electronically supplied data is generally
easier to manage by the local authority and more accurate as there
are less likely to be difficulties such as reading and transcribing
the handwriting on forms.
22. The supply or confirmation of registration
electronically would facilitate the creation of security devices
which themselves would enable electronic voting.
23. Availability and confidentiality
of the register
24. Following the Robertson cases
and the implementation of ROPA the availability of the full register
has been significantly restricted.
25. The limited nature of the permitted
purposes for the use of the full register is causing some practical
difficulties and disadvantages that are the inevitable result
of the widespread use of this information as a proxy national
database. Examples are:
25.1 Although the data may be used to support
credit decisions and for the prevention of money laundering it
may not be used to investigate fraud. Frequently, fraud is identified
post application and after an account has been opened and yet,
commercial organisations are not permitted, under section 114,
to use the information when they are making investigations. However,
public sector bodies may do so.
25.2 Most users accept that it is reasonable
that the full register should not be used to create marketing
lists in order to target people for products and services. However,
ID fraud and, in particular, take over fraud is a growing problem
in the UK. This occurs when a new occupant takes over the ID of
a previous resident. This is a particular problem in rental multi-occupancy
dwellings such as blocks of flats. If the full register were available,
under strict controls, to remove people that are no longer at
an address from mailings etc it is believed that this type of
fraud would be significantly reduced.
25.3 Public sector bodies may already use
the full register for the prevention and investigation of fraud.
However, the limited definition of permitted users has resulted
in a number of public service activities being excluded because
agencies or commercial organisations administer them. Examples
are:
— utilities that are unable to
easily identify the name of the occupier that has absconded leaving
unpaid bills in the name of "the occupier";
— the BBC unable to easily identify
the name of the occupier of a property receiving a TV signal without
a licence; and
— the Environment Agency is unable
to identify people living in flood alert locations and set up
universal warning systems such as a text alert by mobile phone.
This would save valuable time and enable residents to take protective
action to preserve their properties.
25.4 The Provisions of the Act take precedence
over those of other legislation such as the Data Protection Act
1998 (DPA). As a result, notwithstanding an individual giving
their free consent for their electoral register information to
be used only permitted organisations and even then, only for permitted
purposes detailed in the Act, may the data be supplied and used.
A provision for the data subject to give their consent is included
in the DPA and provides an element of future proofing and management
of unintended consequences of regulation. A provision similar
to that in Schedule 2 of the DPA would be a practical solution.
26. Before the advent of ROPA the register
was widely available for any use. It could be examined in public
libraries and Town Halls, by anyone. Since then greater levels
of supervision and control have been required which has resulted
in many local authorities withdrawing the library copies and putting
in place greater levels of control for Town Hall copies as well.
The register is no longer freely available for examination by
the general public in the way that it once was. This could be
addressed by making a National Register (see below) available
in a controlled electronic format on a read only basis via the
Internet and in public libraries. It could be controlled and monitored
and access could also be, in due course, only by use of voter
security controls.
27. Basis for individual registration
eg address-based or on personal criteria such as NI number or
birth date
28. Experian, together with the other CRAs
and the credit industry, was in protracted discussions with the
Information Commission in 2000-01 in an effort to agree a format
that would ensure that personal data was attributed to the correct
person. It has been agreed that the most robust way to uniquely
identify data is for the records to be attributed to a person
as identified by the following:
— Middle name or initial (if they have
one).
— At a PAF[42]
valid or post coded residential address.
29. This has been adopted as an industry
standard and, by October 2007, it is anticipated that all 320
million+ credit records will be held in this format.
30. NI number was not considered to be as
robust and deemed to be unreliable as numbers are duplicated and
reused. Use of NI for this purpose would be a high risk solution
to the issue.
31. The desirability of a national electoral
register
32. The issue of the potential benefit in
the compilation of a national electoral register has been raised
on a number of occasions. During the LASER project the benefit
was deemed to the potential to "sell" the data to commercial
organisations for a range of uses such as marketing and credit
decisioning. A budget of some £16 million was allocated.
33. The underlying arguments did not take
into account the practical requirements of creating, managing
and maintaining such systems which require a high level of sophistication
in the compilation of the history of the data and in the availability
of that information for analysis in order that scorecards may
be developed. A system holding only the current register and capable
of receiving individual enquiries (one at a time) will not be
capable of supporting the needs of the UK's highly developed financial
services industry or those of the public sector.
34. With the implementation of the legislation
limiting access to the full register the potential for making
such a system pay for itself was seriously impaired and the project
stalled. The CORE project appears to be a resurrection of this
concept and was initiated with a budget of £13 million.
35. When LASER commenced both the two major
CRAs advised that they each already hold a highly developed and
comprehensive database of the electoral register which not only
covers the current register but also the historic registers as
well.
36. At that time it was anticipated that
a spend of some £250,000 would be all that was required to
make the changes to include the additional requirements identified
for the database to support the voting and other requirements
of the national electoral register.
37. That proposal was rejected ostensibly
on the basis that the team was uncomfortable with using a commercial
organisation to fulfil such a function.
38. The potential remains for the existing
systems to be adapted for the purposes of supporting the requirements
of the CORE project at a greatly reduced cost to the public purse.
Furthermore, as there are now three CRAs with this data, there
would be choice, competition and back up capability available.
The activities associated with the CORE initiative are part and
parcel of the core business of all three of the CRAs. Working
with them in this regard therefore could be taken forward as a
low cost and low risk option under the Intermediaries Initiative
with all the benefits and savings that would bring.
39. Means of ensuring the security of
the register: PIN numbers, electoral voting cards, signatures
40. Security and ease of access to services
are issues that have been addressed by many financial services
organisations and retailers in order to facilitate account opening
and remote access. In the context of developing e-Government initiatives,
this applies equally ot the public sector. A robust method of
checking the identity of the individual and their place of residence
are key to maintaining security both when setting up access and
security processes and for checking and maintaining it thereafter.
Existing authentication methods could provide a robust and reliable
solution to this requirement by using the existing and historical
electoral registers corroborated by other information.
41. Experian, as a major supplier of application
and authentication systems to the financial services industry
also supports the public sector by providing data for the support
of statutory requirements. Experian's dedicated public sector
capability operates in a discrete environment designed to support
the needs of this important and wide ranging emerging market.
Many local authorities and public bodies already make use of the
experience and expertise built up over 20 years of supporting
and innovating in one of the most advanced and dynamic markets
in the world, namely the UK credit industry.
42. Experian was closely involved in the
regulatory debate during the development of the representation
of the people Act and led the credit industry team in the development
of the case to support the Department of Constitutional Affairs
v Mr Brian Robertson. As such, we, not only as major users
and suppliers of the data but also as an organisation that deals
with the general public on electoral register queries (through
our Consumer Help Service handling 1.2 million queries each year)
are uniquely placed to provide input on the future of the register.
42 PAF-Post Office Address file being the address standard
for a location as adopted by the Post Office and updated each
month. Back
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