Individual Electoral Registration and Electoral Administration - Political and Constitutional Reform Committee Contents

Written evidence submitted by the Credit Services Association (CSA)

1.  The Credit Services Association (CSA) is the only national association in the UK for businesses specialising in debt recovery, tracing and related services. It also incorporates the Debt Buyers & Sellers Group (DBSG), with members ranging from high street banks to credit reference agencies and debt buyers. Our aim is to continually develop and uphold the highest professional standards across the credit industry.


2.  The CSA is in favour of Individual Electoral Registration.

3.  Clause 1 does provide an appropriate legislative basis for introducing IER.

4.  The proposed clause 1(2)(b) does provide for flexibility for any application to be made in any manner that is pre-scribed. The flexibility is dependent upon the appropriate authority remaining abreast of technology and making the order pre-scribing the acceptable manner of the application.

5.  The verification of the address should in our view form part of the registration process. We think this is an opportunity to create an accurate record for the electoral system and the address information should be confirmed by the individual until such times that other means are available.

6.  In line with a desire to see a robust and accurate system, we believe that the confirmation of individual nationality would enhance the accuracy of such a system. As such we are sceptical as to whether or not the current system is sufficient; hence we welcome any proposal that improves the situation.

7.  It is unlikely, in our view, that the system will be perfect from day one. Consequently we believe that it is sensible to begin the transition to IER sooner rather than later. This would allow any flaws in the system to be addressed prior to the General Election in 2015.

8.  We believe that the proposed approach will lead to a reduction in financial crime, in particular fraud. In our view any proposal that will result in a reduction of financial crime is to be welcomed. Therefore we believe that additional thought should be given to the non-mandatory approach. We accept that individuals may decline to provide additional information as there appears to be a reluctance to provide information to the state. This might be overcome if the provision of this information were to be compulsory.

9.  Research from the Electoral Commission has found that appearing on the register was popular where it could be demonstrated that this assisted with the prevention of ID fraud. This is clearly relevant when the registers are used by the credit reference agencies in the granting of credit to individuals. There is an argument that because not all financial crime occurs at point where credit is granted, but during the lifecycle of a credit agreement, use of the register should be permitted throughout the lifetime of the agreement. This would reduce the amount of bad debt within the economy and should ultimately reduce costs.

September 2011

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Prepared 4 November 2011