First Further supplementary memorandum
from Mr Philip Redfern
1. In their oral evidence to the Committee,
ONS argued that mandatory notification of a citizen's change of
address was a prerequisite for a Nordic-style population register
(Questions 202,203,223). However, I feel that they misrepresented
the way that a population register should be created in the UK.
Mandatory notification of change of address might come later as
one of the finishing touches to a population register that was
already up and running. But to put mandatory notification up frontin
an attempt to change national culture by legislationwould
raise a hornet's nest in Parliament and the media. In effect we
would be setting up a road block that would delay implementation
of a Nordic-style system indefinitely. A population register should
be designed to work in the interests of the citizenry. It should
not be designed around legislation that would be uncomfortable
for many people and would probably be widely ignored.
2. A population register should be designed
around the following: (1) the demand that public agencies operate
in a cost-effective manner; (2) the demand (in data protection
legislation) that personal record systems be accurate and up to
date; and (3) citizens' demands for effective and convenient access
to public servicesfor example to be able to notify a change
of address to a single agency which would communicate the change
to all other agencies.
3. Citizens' demands were the starting point
for the ONS-led Citizen Information Project (CIP). The CIP Report
rightly proposed that public agencies should progressively share
contact data in the interim period before much of use emerges
from the Identity and Passport Service's National Identity Register
(I&P NIR). The contact data (also termed core data) comprise
only name, address, sex, date and place of birth and a personal
reference number. Such sharing implies the creation of a population
registerprobably based on the core data held by DWP and
using the National Insurance numbers (NINOs) as the personal reference.
As the I&P NIR built up in the late 2010s, its core data and
the DWP-based population register would be aligned. Incidentally,
there is a good precedent for departments to share contact data:
for decades now Inland Revenue and Social Security have used the
same personal reference, NINOs.
4. Sharing contact data must begin by reconciling
contradictory data in the different agencies' records, and that
involves a great deal of computing and manual interventionand
sometimes reference to the citizen. Once the core data are merged,
updating is secured by daily two-way exchanges of amending information
between the population register and its client agencies.
5. Most citizens are in touch with one or
other public agency from time to time, for example with GRO, DWP,
HMRC, education and health authorities, DVLA, electoral registration
and Council Tax. Citizens are likely to be in touch when they
change address, though for some, particularly among the "hard
to count", there will be delays. On these varied occasions
citizens will communicate changes of address or name etc to the
agency they are contacting, and the changes can then be passed
on via the population register to all client agencies. The key
point is that a central register linking several client agencies'
core data will be more up to date, particularly on addresses,
than any one agency could be if it worked in isolation. The greater
the number of agencies that are linked to the population register,
the more accurate and up to date will the contact data become.
This was the message drummed into me when I toured most countries
of Western Europe on behalf of Eurostat in the 1980s.
6. I don't know whether legislation is needed
to get thus far. Names, sex and date and place of birth are in
the public domain. Research is needed to establish whether sharing
of address and personal reference numbers requires legal authorisation.
(CIP may have studied this.) Regardless of the answer to that
question, I believe we would get most of the way towards an effective
population register without a legal requirement to notify a change
of address. I see such a legal requirement as a finishing touch
intended to convert a de facto working system into a marginally
better de jure system, coupled with an attempt to draw
into the register a minority of "outlaws" trying to
stay out of reach of officialdom. (Incidentally it is already
a criminal offence for a driver to fail to notify DVLA of a change
of address "at once", but one may doubt whether this
is effective in securing prompt notification.)
7. A Nordic-style system embodies an accurate
register of addresses.
8 To sum up, the way ahead is not
to press for early legislation on notifying change of address.
That isn't needed to get started and is a sure way of bringing
the project to a halt. The way ahead is, as the CIP Report advised,
to create a population register by getting public agencies to
share contact data. Naively, the CIP Report passed responsibility
for implementation to individual departments and designated nobody
to be in overall charge.
9. In truth, departments will not have money
in their tight budgets to finance the heavy work of matching and
merging core data. This work will need proper funding. It will
need commitment from the highest levels in government. It will
need a supremo to drive it (and departments) forward. The costs
are very high. But the rewardsboth administrative and statisticalare
much higher still, including perhaps saving the cost of a half
billion pound decennial census.
10. Since CIP reported in 2005 little has
been done to develop plans for a population register (apart from
the longterm plans for the I&P NIR). The longer the delay,
the longer we shall have to wait for better migration statistics
and for an instrument that will support, or possibly replace,
a conventional census.