3 Completeness and accuracy of the
13. We welcome the Government's stated commitment
to take steps to improve the completeness of the electoral registers.
The Cabinet Office and the Electoral Commission are currently
conducting research to benchmark current levels of completeness
prior to the implementation of individual registration, and this
will clearly be necessary to gauge the impact of the change.
14. The introduction of individual electoral registration
in Northern Ireland led to a significant fall in voter registration
levels over the following years. While some of this resulted from
the removal of names that should not have been on the register
in the first place, some eligible people also fell off the register.
The Government hopes that such a situation can be minimised in
Great Britain by carrying forward people already on the register
until after the general election in 2015, giving many existing
electors a second opportunity to register, and the use of data
matching (discussed below), coupled with the absence of any requirement
for each person to re-register and provide personal identifiers
15. We have heard concerns during our inquiry, however,
that some aspects of the Government's proposals risk having a
negative impact on completeness, especially in areas with high
population turnover. The fact that electoral registers are currently
used for setting constituency boundaries makes even levels of
completeness across the country particularly important. Having
large numbers of eligible electors uncounted in future boundary
reviews would also be detrimental to democracy.
REGISTRATION AS PERSONAL CHOICE
16. One of the most controversial aspects of the
Government's proposals is the proposal that "there should
be no compulsion placed on an individual to make an application
to register to vote".
This is on the basis that "while we [the Government] strongly
encourage people to register to vote the Government believes the
act is one of personal choice".
The Government makes the distinction between the current system,
under which the householder's failure to complete and return the
annual canvass form could disenfranchise other electors, and the
proposed system, under which a failure to return the individual
application would have no direct impact on other electors. The
Government proposes therefore that it should remain an offence
in future to fail to respond to attempts by electoral registration
officers to discover who in a household is eligible to vote.
17. The Government also proposes to "allow a
person to respond to an invitation to register by indicating that
they do not wish to be chased", so as to "ensure that
people are not repeatedly asked to register during a canvass period
when they have no intention of doing so and that Electoral Registration
Officers (EROs) direct their resources to finding eligible electors
who want to be registered".
18. There are two issues at stake here. First, should
it be legal for people to choose not to register to vote? Second,
if yes, how easy should it be made for them to opt out of the
19. There is a logic to the Government's argument
for making registration voluntary, but the Electoral Commission
has warned us of possible "unforeseen consequences"
for civic society more generally
The register performs an important civic function,
beyond enabling us to vote, and those functions are also important
in a democracy. It ensures the public are counted for purposes
of representation and drawing boundaries. It ensures that political
parties and candidates can contact electors and try and persuade
them to vote, and of course it is the register from which potential
jurors are drawn. It is also used in law for the purpose of credit
reference agency checks and for detecting fraud.
20. John Turner, from the Association of Electoral
There seems to me a sort of pervasive logic that
gets us to a position where people will drop off the register,
for reasons that have very little to do with voting, politics
or even engagement with the democratic system. They would be persuaded
for other reasons, such as jury service, not wanting to receive
unsolicited mail, wishing to remain anonymousfor all sorts
of security and perhaps other reasons.
21. The Electoral Commission has also expressed strong
concerns about making registration voluntary during the transition
to the new system, describing the proposal as "confusing".
22. In Northern Ireland, under a system of individual
registration, it remains a criminal offence to fail to complete
a registration form when asked to do so. There appears to be no
reason why failure to complete and return a registration form
should be a criminal offence in Northern Ireland but not in Great
Britain. The Government should take steps to remedy this inconsistency.
23. Witnesses were also concerned about the way in
which the Government proposed to make it easy for people to opt
out of being contacted more than once during an annual registration
cycle. The Minister
recognised that many witnesses, including the Electoral Commission
and the Association of Electoral Administrators, had concerns
about the ease at which people could 'opt out' of the current
proposals. The Deputy Prime Minister indicated in the House that
he had some sympathy for those concerns, and giving evidence to
us the Minister stated "we would look at those and change
those provisions when we bring forward the final legislation".
When challenged that the language of the White Paper could 'nudge'
people into not registering to vote, the Minister replied
we will look at that evidence and certainly take
on board the point about whether the combination of the opt-out
and the language nudges, to use your phrase, people in the wrong
direction, because that is absolutely something we are not trying
We welcome the Government's acknowledgment that
care needs to be taken not to make it too easy for people to opt
out from what is still regarded as a public duty, even under the
Government's current proposal that failure to register to vote
should not be a criminal offence. We urge the Government to take
the necessary steps in this direction in the Bill.
24. Electoral Registration Officers have also expressed
concern about the proposal. Julian Bassham from the London Borough
of Southwark, told us "30%-odd of people who eventually we
get registered are not really interested, they only go on for
credit purposes and because we are going to fine them".
Louise Stamp from Tower Hamlets made clear that the current offences
were by no means an empty threat, and were used to get people
to complete annual canvass forms.
In his evidence to us, Chris Ruane MP agreed that the threat of
fines for failure to complete a registration form had significantly
improved electoral registration rates in his constituency.
25. We heard concerns about the impact that this
specific proposal could have on the completeness of the registers.
The Electoral Commission has suggested that registration levels
could fall to match turnout, in other words from around 90% to
as little as 60%.
It is hard to say how accurate this prediction is. Large numbers
of people with no intention to vote would presumably want to remain
on the registers nonetheless, as being listed on the electoral
register is one of the factors used for assessing applications
26. What seems likely, however, is that registration
levels would fall by different amounts in different parts of the
country, depending on their social and economic profile and the
transience of the population. Using estimates based on what percentage
of a constituency fills and returns a canvass form without receiving
a reminder, John Turner of the Association of Electoral Administrators
(AEA) agreed with this analysis, stating that once the 'carry
forward' expires after the General Election in 2015 "in these
sorts of leafy shires you could be talking about a drop of 10%
or 15%. In inner city areas I think ...(a fall of up to 30%) is
somewhere near the mark".
27. Julian Bassham of the London Borough of Southwark
agreed with the AEA's analysis. He told us "the problem is
going to emerge after 2015 when, as an urban inner London authority,
we will see a significant fall-off in the register".
His colleague from Stratford-on-Avon District Council, with a
relatively stable population, was less concerned.
28. We recommend that it should initially be an
offence to fail to complete a voter registration form when asked
to do so by the relevant electoral registration officer. This
should be reviewed after five years of operation of the new system
of individual registration, by which time registration levels
may be high enough and a culture of individual registration sufficiently
embedded for compulsion to no longer be necessary.
29. Under the Parliamentary Voting System and Constituencies
Act 2011, the Boundary Commissions are required to use the number
of names on electoral registers as a basis for drawing constituency
boundaries, with a narrow margin for manoeuvre. If levels of completeness
come to vary significantly between different parts of the country,
constituency boundaries will be redrawn on a basis that may be
perceived as unfairly disadvantaging one party.
30. Unless addressed, this issue is likely to come
to a head in 2015. On current plans, the Boundary Commissions
will be conducting their next review on the basis of the electoral
registers as they stand in December of that year. This is at a
point when those electors carried over under the old system will
have fallen off the registers, but will not yet have needed to
exercise their vote under the new system: the first such electionsto
local authorities and devolved bodiesare likely to take
place in May 2016.
While there is a risk that there will be an ongoing variation
in levels of completeness across the country, as anecdotal evidence
already tells us urban areas have lower registration rates than
rural areas, that
variation is likely to be at its most extreme in late 2015.
31. The Minister did not agree that there could be
a fall in the completeness of the register after the carry-forward
expires in Autumn 2015, and he therefore did not think there was
a risk of the register being inaccurate for the redrawing of boundaries
in December 2015. He told us "It is really the only data
set that you can use for doing boundary reviews because it is
the right group of people, eligible voters. We want it to be as
accurate as possible, both for elections and for boundary review
purposes, so we are very focused on that as well".
32. For the next parliamentary constituency boundary
reviews to be fair and representative, electoral registers across
the country need to be at least as completeand as consistently
completeas they are now. The Government needs to ensure
that its proposals will achieve this end.
33. There is a risk that the electoral registers
in December 2015 will be particularly varied in their levels of
completeness: this matters because they will be used under current
legislation as the basis for the next boundary review. We recommend
using instead the registers as they stood on or before general
election day in May 2015.
GROUPS MOST AT RISK OF FAILING TO
34. Witnesses have suggested that people in groups
that are already under-represented on the registers, such as young
people, electors from some BME communities, home movers, and those
in private rented accommodation, are at particular risk of dropping
off the register during the transition to IER. The Electoral Commission
told us that even under the current system "under-registration
and inaccuracy are closely associated with the social groups most
likely to move home".
35. Simon Woolley, Director of Operation Black Vote,
told us that the introduction of IER would reduce registration
rates amongst the groups he represents, at least initially: "that
is going to happen, we have to brace ourselves for that".
Dr Toby James of Swansea University,
the British Youth Council,
and the National Union of Students raised similar concerns. The
NUS called for "greater powers to the Electoral Commission,
targeting of registration rates, coordinated campaigns together
with local organisations and community groups, such as students'
unions, and engagement with young people still in school or college
even before they are eligible to vote".
36. Louise Stamp, Electoral Services Manager for
the London Borough Tower Hamlets, outlined the work that Tower
Hamlets was doing to try and break down some of the cultural barriers
(38% of the population of Tower Hamlets is Bengali) that some
electors could have with registering to vote individually. She
also highlighted the high turnover of electors in a dense urban
area such as Tower Hamlets made the EROs role particularly challenging:
"we get 60% movements in our annual canvass period, so that
is a massive churn".
We recommend that the Electoral Commission's public information
campaign around the launch of individual registration include
as an important element strands aimed at encouraging those in
groups currently under-represented on the electoral rolls to register
37. The Government proposes that those who are "unable
to provide a national insurance number (NINO) will normally have
to produce two other items of identification from an approved
list, such as a passport or photo driving licence. Those who
cannot provide a form of photographic identification will have
to present themselves to the local electoral registration office
and sign a declaration. Disability charities have suggested to
us that some disabled people, especially those in residential
care, "may not only not have a national insurance number
but also have difficulties in producing alternative evidence such
as utility bills",
while the requirement to travel to an office could also be problematic
for people with mobility or mental health problems.
38. The Minister stated that the Government was committed
to ensuring that every eligible elector could use his or her vote.
He told us the Government would "make sure that, in all of
those groups you particularly mention, no one is disenfranchised".
We welcome the Government's commitment to ensuring that all eligible
electors will be enfranchised.
39. By providing for a variety of ways in which people
can verify their identity, the Government has ensured that most
of those entitled to vote should be able to register successfully
if they want to. There may be a small number of people who
neither have the required documentation nor are able to travel
to an office to attest to their identity. We recommend that the
Government ensure that people in this situation are not deprived
of their right to vote.
IMPROVING REGISTRATION RATES
40. We have heard during our inquiry of a variety
of ways that might help encourage people to register to vote.
41. The edited register is available for general
sale and is used by organisations for commercial activities, such
as marketing, as well as by the political parties for campaigning.
Electors who do not want their details to appear on the edited
register need to opt out. The Ministry of Justice consulted on
the future of the edited register in 2009-10; the Government's
response to the consultation has not been published, possibly
due to the change of Government in 2010.
42. The Electoral Commission and the Association
of Electoral Administrators have both called for the publication
of the edited register to cease. A 2008 survey conducted by the
Local Government Association and the AEA found that "almost
9 in 10 electoral officers surveyed believed that the practice
of selling the electoral register discouraged people from registering
43. Some businesses, notably direct marketing agencies,
rely on the edited electoral register to identify and access customers.
In their written evidence to us 192.com, a people-finding website,
stated that the edited register brings significant benefits to
businesses and charities.
The Credit Services Association, which also incorporates the Debt
Buyers and Sellers Group (DBSG), states that use of the full electoral
register should be made available to debt collection agencies,
as "not all financial crime occurs at the point credit is
granted ... use of the register should be permitted throughout
the lifetime of the agreement".
We thoroughly disagree with the CSA's proposal. Whatever benefit
it might bring, we cannot justify the sale to commercial organisations
of personal details gathered by the Government for electoral purposes.
The Electoral Commission has suggested that if Government decides
to keep the edited register that it should be changed to an opt
in system, instead of opt out. We suspect that this option might
well make the edited register too incomplete to be of much use.
We recommend that the edited register should be abolished.
44. The AEA told us that traditional means of encouraging
registration, even house to house canvassing, have only limited
success in boosting registration rates: "it cost an awful
lot of money to add about 5% of people to the register".
This suggests that it may be worth considering more unconventional
45. One of the main reasons for moving to a system
of individual registration is to improve the accuracy of the registers,
in particular by removing people who are ineligible to vote. However,
they look less likely to be successful in ensuring that entries
which become ineligible are subsequently removed in a timely way.
IDENTIFYING DUPLICATE ENTRIES
46. A central electoral register, such as the one
that is in place in Northern Ireland, would have made identifying
duplicate entries much simpler, but in July 2011 the Government
decided to abandon plans for a Coordinated Online Register of
Electors (CORE) on the basis that it was not "proportionate,
cost effective or consistent with the Government's policy on databases
and reducing the number of non-departmental public bodies".
47. The Electoral Commission and Dr Stuart Wilks-Heeg,
Director of Democratic Audit, both told us that without a central
register, identifying duplicate entries would be difficult and
resource-intensive, and in some cases impossible.
It would not be possible, as in Northern Ireland, to say "if
I looked in at Belfast I could see someone is registered in Londonderry".
48. The Government's alternative to a central database
relies largely on data matching with information held by other
public bodies. We discuss this in detail below.
49. We recommend that the Government explore ways
of improving the sharing of information between local authorities,
especially where potential electors move house.
50. Individual registration should help to reduce
the risk of some types of electoral fraud. The current system
of household registration involves almost no verification of the
data provided in response to the annual canvass, and is thus extremely
vulnerable to fraud. It is unclear the extent to which such fraud
in fact takes place. There does seem to be evidence, however,
of a strong link between electoral register entries and other
forms of fraud. A recent Metropolitan Police Service (MPS) and
National Fraud Initiative Operation Amberhill, analysed identifiers
on forged or counterfeit documents and found that 45.6% of these
were positive matches on electoral register entries, because criminals
had either stolen real identities or added bogus entries to the
register to facilitate fraud.
10 Cm 8108, para 2 Back
Cm 8108, paras 27-28 Back
Cm 8108, para 64 Back
Cm 8108, para 64 Back
Cm 8108, para 74 Back
Q 184 Back
Q 143 Back
Q 188 Back
Cm 8108, para 74 Back
Q 221 Back
Q 228 Back
Q 92 Back
Q 92 Back
Ev w30 Back
Q 201 Back
Q 169 Back
Q 85 Back
Q 82 Back
Q 261 Back
Electoral Commission, The completeness and accuracy of electoral
registers in Great Britain, March 2010, pp 69-70 Back
Q 262 Back
Ev 100 Back
Q 96 Back
Ev w4 Back
Ev w24 Back
Ev w31 Back
Q 81 Back
Cm 8108, para 51 Back
Ev 84 Back
Ev w20 Back
Q 263 Back
Ev 104 Back
Ev w14 Back
Ev w14 Back
Q 158 Back
HC Deb, 17 July 2011, col 71WS Back
Ev 70; Q 199 Back
Q 164 Back
Paras 79-84 Back
Cabinet Office, Individual Electoral Registration Impact Assessment,
Cm 8109, June 2011, p 9 Back