Select Committee on Treasury Written Evidence

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 front—in an attempt to change national culture by legislation—would 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 services—for 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 register—probably 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 intervention—and 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 rewards—both administrative and statistical—are 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.

February 2008

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