Memorandum submitted by the Federation
of Family History Societies
This response comes from the Federation of Family
History Societies, an Educational Charity that represents over
200 Family History Societies worldwide with a membership of more
than 300,000 genealogists and family historians.
The FFHS response is based on the Regulatory
Reform Review Committee's Order of Reference and specifically
refers to criteria [b], [e], [j] and [m].
The FFHS welcomes many of the proposals to reform
the Registration Service that are contained in the White Paper,
but wishes to express its concerns over a number of proposals
that it believes require further examination.
1. The FFHS welcomes the proposal to retain
the occupation on Birth and Death Certificates [21.8.5], but cannot
understand why it is still considered necessary to exclude the
address on copies of Birth and Death Certificates since addresses
are often given in newspaper birth announcements, death announcements,
and in obituaries and reports on inquests.
2. The FFHS welcomes the decision to amend
the restrictions of information on copy Birth Certificates to
less that 75 years and on copy Death Certificates to less than
25 years similar to the Scottish system but still queries whether
these restrictions are necessary as the Scottish system gives
all the information that is on the certificates.
3. One of our Associate members—Association
of Genealogists and Researchers in Archives [AGRA]—is concerned
about the limitations on Authorised Users [21.8.19] and as a group
of professional researchers would wish to be included in the list
of Authorised Users. AGRA is concerned that its researchers would
be severely limited by the exclusion of addresses on copy certificates
if they were not permitted to become Authorised Users. This view
is endorsed by members of the Guild of One Name Studies [GOONS]
who in their specialised research need access to information about
addresses on copy certificates.
4. The FFHS welcomes the proposed reductions
in charges to access the central database [21.8.32], but would
request a clear statement on how long the charges will remain
at this level. The RRO does not give sufficient detail about the
creation of the database, or about quality control and accuracy
and these are matters of major concern.
5. The FFHS is very concerned that there
will be sufficient funding to implement the RRO. While the digitisation
of the registers from 1993-2005 will be mandatory, digitisation
of earlier registers from 1935-92 will depend on what funds are
left. The FFHS urges the Review Committee to obtain a firm commitment
from the Government that there will be sufficient funding to digitise
these registers as well.
6. At the Suppliers Day about DOVE—Digitisation
of Vital Events—held in Liverpool on 3 August 2004, some
of the answers in the handout need further consideration.
6.1 The FFHS is extremely concerned that
it is far from clear which registers are to be digitised. The
registers held by local Registrars are far more accurate and complete
than the copies held by the GRO. The FFHS strongly urges the Review
Committee to insist that the local registers are digitised rather
than the GRO registers. Although cost is a factor, digitising
the GRO registers would be a duplication of effort and would incur
increased costs.
6.2 The FFHS is also extremely concerned
that there is a distinct possibility, on cost grounds, that data
keying will be done "off-shore." This must be done within
the UK given the experience with Qinetiq and the 1901 Census,
despite their quality control system, and the transcription of
this and other Censuses by commercial firms. [The FFHS can quote
many examples of such errors].
6.3 The FFHS is also very concerned with
the response at the Suppliers Day to Q&A 7 that the level
of accuracy will only be that which is affordable by the company
winning the tender. The FFHS urges the Review Committee to insist
that the accuracy of the indexes is the highest possible as this
is a vital element in historical research. If errors are not corrected
at the time of digitisation and transcription they will never
be located later.
7. The FFHS is concerned that the RRO is
vague about the preservation of the historic registers, ie those
prior to 1935. The Archives Services do not have sufficient storage
facilities or staffing to take in the registers. The FFHS wishes
to see consistency of access across England and Wales, and urges
the Review Committee to obtain a commitment from the Government
to ensure that sufficient funding is provided to make this possible.
8. The FFHS is concerned that the RRO gives
no indication that The National Archives [TNA] has been consulted
about digitisation and the creation of a national database [21.7.16].
The expertise of the TNA in digitisation, databases and records
management should be fully exploited.
9. The FFHS is also concerned that the RRO's
access framework ignores the Freedom of Information Act [21.8.60]
and queries whether the Information Commissioner has been consulted
in drafting the RRO. The FFHS urges the Review Committee to revisit
this area of concern.
The FFHS agrees with 21.10.26 that the RRO offers
exciting opportunities for the digitisation of historic records.
This is a once in a lifetime opportunity for the Government to
provide an accurate index of Birth and Death records, high quality
digitisation and a consistent and high level of accessibility.
The FFHS urges the Review Committee to ensure that this is the
end result.
The FFHS is more than willing to appear before
the Review Committee, if invited, to discuss more fully concerns
made in this submission.
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