Written evidence submitted by Mrs Amanda Edwards [ELR 010]

Advantages of the existing system of electoral registration:

● It is Free to the citizen to register to vote

● Providing you have your National Insurance number to hand - registering online is a quick, simple process that can be carried out at any one time

● The citizen can take ownership of their registration and update at any one time

● Being on the Electoral Register will aid your credit scoring

● For administrators it is a much less labour-intensive process that generates far less paper and requires less administration support

● We have been able to outsource the registration side, so that the citizen has the choice of responding online, via text or the traditional paper version of the form

● We are now able to data match the register against other data sets such as Council Tax, Housing Benefits and Payroll

● The current system allows the Electoral Registration Officer to engage with residential and nursing homes, doctors’ /nurses’ quarters, students and the travelling community whilst automatic registration would not

● Sending yearly forms, allows queries to come direct to the Elections office such as if someone has gone to prison, travelling abroad for some months or is long term in hospital and answering queries on foreign nationals and their eligibility

Disadvantages of the existing system of electoral registration:

● You have to have your National Insurance number to hand in order to register, otherwise it is rejected, and we have to invite the citizen to submit evidence or go down the attestation route if necessary

● Once you complete the Household form, you will be sent a Register to Vote form, the citizen is confused by this and deems it a bureaucratic system

● Those households that have data matched, do not have to do anything with the form we send them, unless there are changes but we do not know if they have read it and hence if there are any changes

● Because of the above administrators cannot put their hand on their heart and say they have produced an accurate register

● For areas that are quite stagnant in relation to movement (such as Carmarthenshire), majority of households do not move or require updating each year, hence it is a waste of money- should be able to just concentrate on those built-up areas where movement is far more frequent

● The citizen believes that if they are registered for Council Tax then they are registered for electoral roll purposes

● Citizens “play the system”. Now that second homes have an additional charge on them in addition to the council tax, many citizens with second homes will register in two different places i.e. the husband will register in London for example their more permanent home and claim the single council tax discount and the wife will register at their second home and claim the single council tax discount there too- as they think the Council Tax and Electoral Register is linked- they register separately on the electoral register too.

● It is still a costly process producing a form/letter for every household, postage, scanning bureau costs and sending of Individual Registration Forms

How does the system of individual Electoral Registration compare to an automatic or assisted system of voter registration?

●Individual registration gives ownership and responsibility to the citizen, whereas automatic registration takes that away

●Individual registration will give those citizens who are fearful of their address being made public the opportunity to register via anonymous registration. This option of automatic registration would jeopardise that – there would have to be a system of opting out

● Individual registration ensures that every household receives some form of communication from the election’s office, automatic registration could disadvantage those that do not hold a passport, driving licence or have bills in their names if it is inclusive in their rent

● Individual registration requires a once-a-year contact, automatic registration does not mean that the records used are up to date e.g. a driving licence might be in someone’s name but they might have developed a neurodegenerative disease such as Alzheimer’s and hence not be capable of voting

● Individual registration also gives the citizen the option of applying for a postal/proxy vote, this is taken away with automatic registration

● Individual registration gives the citizen the option of opting out of the edited register, this is taken away with automatic registration. If you were then having to write to every elector post update to invite them to opt out, then there is little savings.

Countries that have high levels of electoral registration and lessons to be learnt

Canada has high rates of registration. They have a centralised database called Elections Canada which not only requires over 40 government agencies to update its voter database for Federal elections and Referendums, Provinces also maintain their registers. Elections Canada’s website is like a one stop shop of information on how to register on both registers, election past and forthcoming and even a Teachers Corner. Their registration levels run at approximately 92%.

California is also an example where automatic registration takes place. Eligible applicants completing a driver licence, identification (ID) card or change of address transaction online, by mail or in person at the Department of Motor Voter will be automatically registered to vote by the California Secretary of State, unless they choose to opt out of automatic voter registration. They also use their equivalent of Royal Mail and receive data on those householders who have moved and have a forwarding address. On the introduction of this automatic registration, voter registration rose from 78% to over 81%.

How can existing public data and digital methods be better utilised to create a more joined up electoral registration system?

One suggestion is that we pull all the public data under one umbrella- almost like having a government led “one account” where they are provided with a once in a lifetime unique reference, this “one account” could then be used for a history of records such as the citizen’s Income Tax and National Insurance history, applying for a driving licence, passport or Income Support, student grant and Register of Electors.

What issues exist regarding cyber security, data and privacy?

Outside of my expertise but it is also about providing that assurance to the public that such portals are safe.

What issues to electoral registration officers face in relation to electoral data, including access to and sharing of data?

There is a reluctance with our local university to share information on students. They have readily available data on first year students who are in university owned accommodation but do not have that data on second/third year students. Also, a reluctance with hospital accommodation office on doctors living on site.

It is difficult to obtain information that has all your requirements i.e., full name, DOB, address, nationality and NI.

Internal data is often not up to date. Our Council Tax department are running at roughly three months behind.

We commence the annual update of the Voters’ Roll in July- by the time we come around to the following May’s election the register is way out of date apart from the fact we process the deaths’ list on a weekly basis we are relying on the citizen updating their records if they have moved/married.

What are the challenges presented by event-led registration, and what additional burdens does this place on local authorities?

Electoral Teams are often very small and do not have the capacity to organise a local event led registration day/period. On occasions where we have carried out such events, they have not been very successful compared to the time and effort put into the event.

National led events create more applications coming through, however many of these are duplicate registrations where the citizen believes they have to register again – particularly if the event is pre an election, this puts a heavy administration burden on the elections team.

How have the changes introduced by the Elections Act 22 impacted on EROs?

In Wales it has widened the gap on divergence which us administrators find confusing, challenging and worrying. We are yet to cascade these changes to the public and will hopefully learn lessons from our colleagues in England that have elections.

Areas of concern with regards Voter ID is :

● Messaging – for the next two elections our theme will be you must have ID, then for the next two elections after that (Senedd and Local Elections), you don’t need ID. There is also the bi-lingual aspect of any messaging- great concern for such correspondence as poll cards.

●Staffing at polling stations- there is already an issue with people not coming forward to work in polling stations, the extra responsibility around Voter ID will discourage our existing staff database. Will involve a lot more training of staff.

●Turnout effect-worry that individual authorities will be “blamed” if lots of electors turned away from polling stations compared to neighbouring authorities.

Areas of concern with regards Postal and Proxy Voting:

● Divergence issues here around how to apply for a postal- online for PCC and Parl and paper version for Senedd and Local- fear of numbers dropping off for the latter election types.

● Validation period of existing postal votes being different for national and devolved elections.

Areas of concern with regards Overseas electors:

● Flood gates being opened for volumes of applications

● The Time involved with checking older electoral records of an overseas elector application

EU Citizens:

● We require more information on how this will work

How best can Government support local authorities to alleviate additional burdens and improve accuracy and completeness of their registers?

The Government could make it mandatory that we have access to such records as those held by DVLA, NHS, Passport Office and General Registrar records. These additional data records would be beneficial for data matching.

Have the Governments’ recent reforms done enough to improve the annual canvass process or are further changes required?

Individual Electoral Registration was introduced in 2014 and alleviated a great administrative, costly burden to local authorities. However, the two phased approach to registration is seen as bureaucratic and outdated by the public.

We are data matching against limited records that are available to us, some of which are not up to date at the time of data matching. As a result, we are sending households a letter where there has been a data match and they don’t need to do anything further, however we have no audit of whether that householder has received or indeed read the letter, hence we could be missing vital information.

Those households that are required to respond are what we call the “hard core” they are the households that we have always had difficulty canvassing and are unlikely to register due to many different reasons such as learning difficulties, not interested in voting, don’t want to be found, fear of the forms not being genuine and having a grievance against their local authority.

I believe it is now time for automatic registration. It will benefit the citizen in having assurance they do not need to do anything further with electoral registration and it might encourage them to vote when that poll card comes through the door.

For the administrator it will save a lot of money on their budget- money that could be spent proactively ensuring that citizens keep their records up to date.

What are the barriers to eligible electors registering to vote?

● Time

● Fear that we are linked to other departments – external and internal – hence loss of benefits e.g., if they declare a partner is living with them

● Do not see the point if they are not interested in voting

● Lack of understanding that they have to register before a certain date- many think they should be able to register on polling day

● Citizens who believe that their vote doesn’t make a difference so why register

● Religion

● Many rental agreements are short term or deemed as temporary/semi-permanent and citizens renting in those circumstances do not class that flat/house as their “home”, hence they do not have that sense of belonging and identifying as the householder. They therefore ignore any communication from the Elections Office to register to vote.

Why are there so many inaccurate entries and duplications on the register?

I believe this record of inaccuracy is not reflective across the country. Areas of dense, rental, HMOs, social housing where movement is constant will have inaccuracies as it is challenging to canvass these properties. 

Local Authorities that have areas which are rural and/or have an ageing/retired population will have more accurate records.

We have had suspicions with a lot of rental accommodation that the flats are sub- let and hence the current occupier is reluctant to engage with us. Some landlords are also reluctant to give you information on their rental accommodation.

Citizens who are claiming benefits particularly where they receive the maximum due to having a young family and being the only supporting adult, will not declare a partner moving in as they fear they will lose some/all of their benefits.

There is confusion particularly leading up to an election where national advertising misleads electors to think they have to register for the upcoming election even though they are registered.

How can resources be better targeted to ensure better engagement and accessibility for certain demographics?

We could employ a full time Engagement Officer that worked with schools, nursing/residential homes, Apprenticeship schemes, local big employers, food banks, estate agents, rental companies – to name just a few. The person would work continuously in the community ensuring that we cascade the message of registering to vote and keeping your detail up to date.

March 2023