Readiness for the transition to Individual Electoral Registration

Transcription

1 Readiness for the transition to Individual Electoral Registration Progress report March 2014

2 Contents Summary Background Progress made since our October 2013 assessment of IER readiness The last household canvass Performance of EROs: planning for and delivering IER... 21

3 Summary Significant progress made; work still to be done In October 2013 we published an assessment of readiness for IER, which set out our assessment of whether sufficient progress had been made with the implementation process for IER for the necessary commencement order to be signed, bringing the transitional provisions for IER into force for England, Scotland and Wales from June Our assessment set out where concerns still remained and how we expected them to be managed in order to give sufficient assurance that IER will be delivered in a way that best meets the interest of voters. In particular, the Commission remained concerned about the robustness of the IT systems and about funding allocations. Although our assessment recognised that some risks remained which needed to be addressed, we recommended that the UK Government proceeded with the implementation of IER starting from June Subsequently, in December 2013, Rt Hon Greg Clark MP, the Cities and Constitution Minister, made a Written Ministerial Statement that the introduction of IER in England and Wales will begin in June 2014 and in Scotland will begin in September Since our last assessment of IER readiness, significant progress has been made. While the Government still needs to do more work to assure Electoral Registration Officers (EROs) that the required IT system and contingency arrangements are fully in place ahead of the start of the transition to IER in June 2014, other areas of concern such as the allocation of funding to EROs have now been resolved. The transition to IER will be supported by some key IT systems to match existing electoral registers against the DWP database in the initial confirmation exercise; to check the personal identifiers on new applications to join the IER register against the DWP database in the on-going verification process; and to allow people, for the first time, to apply online to join the register. On IT, while significant progress has been made and the important end to end test of the system is still scheduled to be completed by 31 March, the time pressures which we identified in October remain very challenging. From now on there is very limited scope for coping with unforeseen circumstances or resolving significant problems. Encouragingly, the Cabinet Office has good relationships and agreements in place with the key delivery partners that are needed to deliver this work including Government Digital Service and the Department for Work and Pensions (DWP). It will be important for all those involved in preparing the IT systems for use to support the Cabinet Office fully in this final phase. 1

4 As soon as possible, it will be important, in ensuring ERO confidence, for the Cabinet Office to be able to say publicly that the IT systems to support IER are fully ready for EROs to use. However, there can never be 100 per cent certainty that the systems will work at every stage. Progress has been made in the development of contingency arrangements but full information on contingency planning and the technical support available to EROs during the transition has not yet been shared with EROs. The Cabinet Office should finalise the detail of this work and communicate it to EROs and their staff as soon as possible. If full plans are not to be released shortly, then the programme should tell EROs when they can expect them and what they will cover. In the case of both the IT system and contingency arrangements, the Commission will continue to monitor progress closely. Preparations by EROs EROs in England, Scotland and Wales have now concluded the final household registration canvass before the transition to IER starts from June 2014, taking steps to ensure their registers are as accurate and complete as possible in preparation for the change. Our assessment of EROs performance at the canvass against our existing household registration standards found that the vast majority met or exceeded all of the standards. However, five in England did not meet our house-tohouse enquiries standard in 2013 (down from 30 that did not meet the same standard in 2012). House-to house canvassing is a crucial element in ensuring the registers are as accurate and complete as possible during the transition to IER; the Commission is therefore working with those EROs to ensure they have plans in place for household canvassing as part of the move to IER. EROs will play a critical role in ensuring that the transition to IER is delivered effectively. While the transition does not begin until June, EROs have already been undertaking considerable work in preparation for the change, developing local public engagement strategies which identify the challenges for their particular local area and what mechanisms they will use to engage with residents to maximise registration. We have been monitoring performance against our IER performance standards designed to support EROs in preparing for and delivering the transition to IER and we are now confident that all EROs have the necessary strategies and plans in place to be able to meet the challenges of IER in their local area. However, while there has been considerable good work completed to date, it is essential that momentum is maintained and that EROs continue to focus their efforts on preparing for and delivering the transition successfully. 2

5 Monitoring the progress of the transition Throughout the transition to IER, we will be monitoring progress, collecting data from EROs to enable us to assess and report on the impact of the transition. Following conclusion of the confirmation live-run the exercise where electors details are matched against details held on the DWP database to identify which electors can be automatically transferred to the new IER register we will be able to identify the local authorities and individual electoral wards which have the lowest rates of matched electors and are therefore the immediate pressure points. We will also know the extent of postal voters who have failed to match and so are at risk of losing their absent vote at the UK General Election in May After the conclusion of the write-out and 2014 canvass, we will collect detailed, local authority-level data from every ERO including the numbers of electors on the registers who have not been confirmed and have not yet registered individually using personal identifiers. This data will allow us to assess how the transition has progressed from the end of the confirmation exercise up to the publication of the revised registers. Importantly, by collecting the data from every ERO we will be able to see any significant variations across the country. We will therefore be able to assess whether areas which had lower match rates in confirmation, which we therefore expected to face a greater challenge in managing the transition to IER, also have a greater proportion of electors on their registers in December 2014 (March 2015 in Scotland) who would be removed at the end of the transition period. In June 2015, we will report on our assessment of the effectiveness of the transition up to that point, with a view to informing the Ministerial decision, which will need to be taken very soon after the UK General Election in May 2015, on whether to bring the end point for IER transition forward from the current date in December 2016 to December Our assessment will be underpinned by a clear understanding of what the effect on the registers would be of ending the transition in December 2015 and therefore removing those electors not yet registered individually at that point. It will be essential that EROs understand what their data is telling them about the progress they are making in registering people under IER, and that they revise their activity accordingly to build on what is effective and address what is not working so well. We will continue to work with the Cabinet Office to support EROs in preparing for the transition and in refining and updating their plans as necessary throughout the period of the transition, with a particular focus on those who we believe may need more targeted support to ensure that IER is implemented successfully. 3

6 1 Background 1.1 At present, in England, Scotland and Wales, one person in every household is responsible for registering everyone else who lives at that address. The Electoral Registration and Administration Act 2006 (ERA Act) provides for the introduction of individual electoral registration (IER) in Great Britain, a change that the Electoral Commission has been calling for since With the introduction of IER from June 2014 in England and Wales, and September 2014 in Scotland, each person will be required to register to vote individually, rather than by household. 1.2 Changing the electoral registration system requires careful planning which in turn will help to facilitate effective implementation, all of which needs to be done in a way that puts the voter first. Electoral Registration Officers (EROs) have a critical role in delivering IER and the Commission has been working closely with the Cabinet Office to support them in planning for and delivering the transition. Our assessment of IER implementation readiness October In October 2013 we published an assessment of readiness for IER, which set out our analysis of whether sufficient progress had been made with the implementation process for IER for the necessary commencement order to be signed, bringing the transitional provisions for IER into force for England and Wales from June 2014 and for Scotland from September Our assessment set out where concerns still remained and how we expected them to be managed in order to give sufficient assurance that IER will be delivered in a way that best meets the interest of voters. In particular, the Commission remained concerned about the robustness of the IT systems and about funding allocations. 1.5 Although our assessment recognised that some risks remained which needed to be addressed, we recommended that the UK Government proceeded with the implementation of IER starting from June In December 2013, Rt Hon Greg Clark MP, the Cities and Constitution Minister, made a Written Ministerial Statement that the introduction of IER in Great Britain will begin in June This report 1.6 This report summarises progress made since October 2013, with a particular focus on the work that has been undertaken by EROs. 1.7 Chapter 2 covers general progress made since our assessment of readiness for IER in October 2013 and outlines our assessment of the 4

7 progress that has been made in addressing the risks we identified relating to funding allocations and IT systems. 1.8 Since October 2013 all EROs in Great Britain have completed the final annual canvass under the household-based registration system, and chapter 3 of this report gives an assessment of the performance of EROs against the Commission s performance standards relating to household registration. 1.9 EROs have also undertaken considerable work in planning for and preparing for the implementation of IER later this year, and chapter 4 covers our monitoring of EROs preparedness for the transition Chapter 4 also sets out what further work will be undertaken to monitor the work being undertaken by EROs and the overall effectiveness of the transition. This includes a summary of the data we will be collecting and when, and what this should tell us on the progress that is being made across England, Scotland and Wales to maximise the number of electors registered individually. 5

8 2 Progress made since our October 2013 assessment of IER readiness 2.1 Our assessment of readiness for IER, published in October 2013, recommended that the UK Government proceed with the implementation of IER from June But we recognised that there were some risks which remained and which needed to be addressed. In that report we set out our remaining concerns and how we expected them to be managed in order to give sufficient assurance that IER will be delivered in a way that best meets the interest of voters. 2.2 We have reviewed progress made since October. We continue to believe that none of the issues that we have identified require the implementation of IER to be delayed, but we highlight below two key areas which require extremely close management from the Cabinet Office from now on. 2.3 Many of the significant issues raised in October have now been resolved: In October, the detail of the funding to be made available by the Government to support EROs work during the transition to IER had not been made public. All EROs are now aware of the level of funding they will receive and our discussions with them suggest that they do not have significant concerns in this area. The design and detail of the main registration forms to be used under IER had not yet been approved; these have now been finalised and made available to EROs. 1 The timing for key activities - such as the period within which EROs will write out to unconfirmed electors - had not been established; this has now been agreed. 1 With the exception of the forms to be used by crown servants, overseas electors, anonymous electors, service voters, those with no fixed/permanent address and by anyone wishing to change their name on the register, which are still to be approved and published. This is expected to be completed shortly. 6

9 IT development 2.4 In our previous assessment, we identified two specific areas of concern around IT: The development and testing of the verification system (used by EROs during the application process to check the personal identifiers including the national insurance number - of individuals applying to register to vote) The development and testing of the online registration portal (used by people who want to apply online to join the IER register) Testing 2.5 Our primary concern in October was around the time available for the testing of the verification and online registration systems following the development work, and the fact that while testing was to take place on a rolling basis throughout development, the full testing of the end to end system (ensuring that the system as a whole works as envisaged and can send data from and to the places intended) was not scheduled until March We were concerned because this left little time between March and June 2014 to put right any problems that do emerge from this test, before both systems start to be used. 2.6 Up-to-date plans from the Cabinet Office indicate that, although this testing began just over two weeks behind schedule, it will be completed by 31 March. At this point we have not seen any results from the testing and the scale of any additional work is therefore unknown. 2.7 Further testing will take place at the conclusion of the end to end test. It is planned for completion at the end of May This further work includes elements of performance testing (ensuring the system can run at full capacity for a sustained period) and testing to ensure that the system can be re-started if there is a failure. 2.8 As at the date of this report, therefore, the IT infrastructure has not been fully tested. The time pressures which we identified in October remain very challenging. From now on there is very limited scope for coping with unforeseen circumstances or resolving significant problems. Encouragingly, the Cabinet Office has good relationships and agreements in place with the key delivery partners that are needed to deliver this work including Government Digital Service and the Department for Work and Pensions. It will be important for all those involved in preparing the IT systems for use to support the Cabinet Office fully in this final phase. 2.9 As soon as possible, it will be important, in ensuring ERO confidence, for the Cabinet Office to be able to say publicly that the IT systems to support IER are fully ready for EROs to use The Commission will continue to monitor progress closely. 7

10 Contingency and technical support to EROs 2.11 We said in our October assessment that, because IER is heavily dependent on a functioning IT system, it will be important that realistic and robust contingency plans are in place to deal with partial or complete failure of the IT system after the start of IER We have discussed these contingency arrangements with the Cabinet Office since October but at this point the necessary robust plans have not been finalised. This is a concern because, as in the case of the delayed system testing, the lack of known contingencies has the potential to undermine the confidence of EROs and their staff who will be working to deliver IER It is important that, even in the absence of IT failures that require full contingencies, EROs and their staff know how to resolve technical issues related to the IER IT infrastructure. We are aware that the Cabinet Office has been developing their plans for supporting EROs in resolving any technical issues which do arise during the transition. This includes, for example, who an ERO should approach in order to get a particular type of issue resolved and how quickly they can expect the problem to be fixed The detailed information on contingency planning and technical support during transition has not yet been shared with EROs. The Cabinet Office should finalise the detail of this work and communicate it to EROs and their staff as soon as possible. If full plans are not to be released shortly, then the programme should tell EROs when they can expect them and what they will cover The Commission will continue to monitor progress closely. Electoral management software and connectivity 2.16 The development of the electoral management software (EMS) systems which are used by EROs to maintain the registers has been an important stream of work in developing the IT for IER which has also proceeded largely to the intended timescale. There remains some work to be completed, and the Cabinet Office has indicated that development and testing should be complete by mid-april. We have no reason to believe that this will pose any significant problems however it remains possible that the testing will highlight additional required work and the Cabinet Office should therefore manage this process carefully through to completion There are two other issues. Firstly, the updated EMS systems need to be successfully rolled out to EROs and their staff across the country. This rollout is scheduled to take place, at least in part, in the run up to the May 2014 elections, and so it needs to be managed carefully in order to limit the risk to the successful delivery of both the May polls and IER. 8

11 2.18 Related to this, there is a growing concern among the electoral administration community around how much time they will have to familiarise themselves with the new systems before 10 June, particularly in light of the elections on 22 May The Cabinet Office and the EMS suppliers should be clear and specific with EROs and their teams on when they should expect to have the new systems in place at local level. We welcome the fact that training on these new systems will continue to be available to EROs and their staff after the May elections Secondly, each ERO will need to have their local EMS system connected to the central IER system. Initial experience of this suggests that there will be a range of mostly minor issues that will mean many of these connections cannot be established immediately the minor issues will have to be addressed first As with the local roll-out of the EMS updates we have no reason to believe that this cannot be accomplished in the time available, but there will be challenges and a risk of unforeseen problems; the Cabinet Office and EMS suppliers must manage this roll-out closely and ensure that all issues are immediately and successfully dealt with. Public Services Network (PSN) 2.22 In our previous assessment of IER readiness, we acknowledged the potential risk to IER of the separate programme of work within Government to migrate all local authorities from the current GCSx secure IT network to the new PSN and we welcomed the communication between the two relevant programmes within the Cabinet Office. This communication has been important in ensuring that this has not become a significant problem particularly as the deadline for moving all authorities onto PSN has slipped significantly and now looks likely to extend past the start date for IER A key risk in the roll-out of PSN was that in moving a local authority over from one network to the other, their ability to connect to the central IER system would be affected. If this happened before the start date for IER this would mean additional work, potentially at both a local and national level, in re-establishing a connection However, this would be an even greater issue if connection problems emerged because a local authority moves from one network to the other during the live run of confirmation We therefore welcome the fact that, in response to the concerns raised by the Commission and others, the IER and PSN programmes have agreed: to allow any authority which has not been successfully migrated to PSN to be able to continue to connect to the central IER system via their existing GCSx connection 9

12 that no local authorities will be transitioned from GCSx to PSN during the confirmation live run 2.26 However, we understand that specific dates for this freeze in migrations have not yet been agreed. As with many of the other issues outlined above, there is a risk to EROs confidence if this remains unresolved. The two programmes should reach agreement on this before the end of April Legislation 2.27 Our October assessment also noted that there were two outstanding statutory instruments (SIs) to support IER. These instruments would allow: Political parties to have access to information about confirmed and nonconfirmed electors in order to enable them to support efforts to ensure all electors are registered individually For data sharing between upper and lower tier local authorities (i.e., allowing a district council to access data held by a county council) 2.28 The first of these SIs has still not been laid. This therefore remains an area of concern as there is significant potential for the work of political canvassers to have a positive impact on the registers during the transition to IER The SI on data sharing was laid on 24 March and the Cabinet Office have told us that they are confident it will be in place by 10 June. It is, however, important that EROs who will be able to take advantage of this change are aware that it is coming. The Cabinet Office should ensure that all EROs are fully aware of the opportunities that this data-sharing order will bring, so that they have plans in place to maximise the use of this new data; and should ensure that the upper-tier authorities are fully aware of the obligations they will have to support EROs in lower-tier authorities. 10

13 3 The last household canvass 3.1 It is particularly important that EROs do all they can to ensure that their registers are as accurate and complete as possible before the transition to IER begins by taking all available steps, including carrying out house-to-house enquiries and using available local data to identify and target potential electors. 3.2 The first stage of the transition involves a data-matching exercise which will compare existing electors details with the details held on the Department for Work and Pensions (DWP) database a process known as confirmation. This will take place during June and July 2014 in England and Wales, and September 2014 in Scotland. 3.3 Where an existing elector s details are confirmed through data-matching, that person will be individually registered by the ERO without the need for the elector to take any further steps. EROs can also carry out local data-matching using local data sources to supplement the matching against the DWP database in order to maximise the number of electors who can be confirmed. Electors whose details cannot be confirmed will need to be invited to register individually. 3.4 The more accurate and complete the registers are before the confirmation exercise, the greater the number of electors who we expect will be confirmed as individually registered without needing to do anything further. This will in turn help to reduce the number of electors that EROs will need to follow up with and invite to register individually. 3.5 A key part of the preparation for IER was therefore ensuring that the final canvass before the transition begins was as accurate and complete as possible. Ordinarily EROs must carry out an annual household canvass and publish the revised register by 1 December each year. However, in preparation for IER and to reduce the period of time between the completion of the canvass and the start of the confirmation exercise, the 2013 canvass was postponed so that it began in October 2013, and EROs were required to publish their revised registers by 17 February 2014 in England and by 10 March 2014 in Scotland and Wales. 11

14 ERO performance in the last household canvass 3.6 The Commission first published performance standards for EROs 2 in July 2008, and has monitored and reported on the performance of EROs against these standards in each year since. 3.7 The following table sets out the 10 household registration performance standards for EROs in Great Britain 3 that we used to monitor performance at the last household canvass. Table 1: Household registration performance standards for EROs in Great Britain Subject area Completeness and accuracy of electoral registration records Integrity of the registration process Encouraging participation in the registration process Planning and organisation Performance standards PS1. Using information sources to verify entries on the register of electors and identify potential new electors (referred to in following charts and text as Information sources) PS2. Maintaining the property database (Property database) PS3. House-to-house enquiries (House-to-house) PS4. Maintaining the integrity of registration and absent vote applications (Integrity) PS5. Supply and security of the register and absent voter lists (Supply and security) PS6. Public awareness strategy (Public awareness) PS7. Working with partners PS8. Accessibility and communication of information (Accessibility) PS9. Planning for rolling registration and the annual canvass (Planning) PS10. Training 2 Under Sections 9A and 9B of the Political Parties, Elections and Referendums Act 2000 (PPERA), as inserted by Section 67 of the Electoral Administration Act The existing household registration performance standards for EROs, July

15 3.8 When we reported on EROs performance in we were concerned about some aspects of performance, principally in relation to standard 3: house-to-house enquiries. While there had been an improvement in performance against this standard since 2011 when 58 EROs (15%) did not meet the standard, there were still 30 EROs (8%) who did not meet the standard in In addition to performance standard 3, there were three EROs who did not meet performance standard 6: public awareness in We asked all EROs to report to us on their performance against the household registration standards in August 2013 in advance of the canvass, and as part of this we required all EROs who were not meeting the standards in 2012 to provide supporting evidence to us to demonstrate their performance. Following this, we have been working with individual EROs where their returns and other available information indicated that they may not be meeting one or more of the performance standards to identify and recommend improvements that could be made, with a view to ensuring they took the necessary steps to be able to meet the performance standards We also asked all EROs to provide additional contextual data following the conclusion of the canvass to enable us to make a better-informed assessment of each ERO s performance against the standards. EROs in England were required to complete the data return by 28 February 2014, and EROs in Scotland and Wales by 21 March This additional data included: overall registration rates the annual canvass response rate levels of carry forward of electors numbers of changes to the electoral register numbers of households which had not had entries confirmed by taking steps under Section 9A of the Representation of the People Act 1983 (RPA 1983), including through making house-to-house enquiries Timing of this report and publication of data 3.12 Given that the canvass was completed only very shortly before the publication of this report, our detailed analysis of the electoral registration data, which informs our assessment of ERO performance, is still under way We expect that, as was the case in 2011 and 2012, our data analysis may identify some EROs whose canvass activity did not, in practice, meet 4 data/assets/pdf_file/0005/155417/report-onperformance-of-electoral-registration-officers-in-2012.pdf 13

16 standard 3. 5 Our assessment of performance against standards 1 (information sources) and 3 (house-to-house) in this report is therefore based on the information currently available to us, and is subject to confirmation once we have completed our detailed analysis of the electoral registration data from the 2013 canvass We will publish the full 2013 canvass data set in May once we have concluded our analysis, along with our final assessments of EROs performance against the standards. Summary of performance 3.15 Our assessment of EROs performance at the canvass against our existing household registration standards found that the vast majority met or exceeded all of the standards. However, five did not meet standard 3: houseto-house enquiries in 2013 and one did not meet standards 6: public awareness and 7: working with partners These three standards, along with standard 1: information sources, cover the key aspects of electoral registration work under the household registration system which will continue to be of significant importance looking ahead to the transition to IER. This report therefore focuses on performance in these areas, taking account not only of what was done during the last household registration canvass but also what will need to be in place to support the effective delivery of the transition to IER. Performance standard 1: Information sources 3.17 This standard aims to ensure that EROs use appropriate sources of information to verify records on the register of electors and to identify and contact potential new electors throughout the year. EROs are entitled to inspect any records held by the council that appointed them, such as council tax records and housing records, and can also inspect records produced by the registrar of births and deaths. Access to these records serves a dual purpose: to identify potential new electors; and to check that registered electors continue to be eligible to be registered Using local data will be particularly important under IER in order to: supplement the confirmation process (see 3.2 and 3.3 above) identify new potential electors and invite them to register 5 In 2012, 21 EROs initially reported meeting the standard but we revised their assessments to not meeting following our detailed analysis of the supporting data and additional evidence. 14

17 identify where an elector may no longer be eligible to be registered (for example, because they have moved out of the area) support the process of verifying an elector s identity when they make a new application to register Following the dry run of the confirmation process in summer 2013, many EROs conducted further work in order to determine how their confirmation rate could be improved by further matching with local data. The results from this exercise suggested that there could be substantial benefit to EROs in carrying out a local data matching stage once they have received the results of their matching against the DWP database. Among those that reported data to the Commission, the average increase in their overall confirmation rate was 6-7%, although there was significant variation in the results. In response to a survey issued by the Commission, 91% of EROs said that local data matching would be important during live confirmation As in 2012, all EROs reported that they are either meeting or exceeding this standard in 2013 by proactively identifying and using the records they are entitled to inspect, throughout the year, including during the annual canvass period, to verify and validate data held on the electoral register As part of maintaining an accurate register throughout the year, EROs should be conducting registration reviews to remove electors they have identified through inspecting other records as being no longer entitled to remain registered for example, where checking against other records has identified that the individual has moved address and is no longer resident at the address they are currently registered at. Under IER and with the move away from an annual household canvass, reviews will become the main mechanism by which redundant entries will be removed from the electoral register We are in the process of reviewing the data EROs have provided following the conclusion of the canvass to understand what work has been carried out in conducting registration reviews in practice to date and will use this to identify where any further guidance or support is needed to ensure that all EROs are fully prepared to be able to carry out reviews once the transition to IER has commenced. 6 People applying to register individually are required to provide their national insurance number and date of birth, which must be verified by checking against DWP data. If the person s identity cannot be verified through this process, EROs can also carry out local datamatching using reliable and robust local data sources to verify the applicant s identity. 15

18 Performance standard 3: House-to-house 3.23 EROs are required by law to take all steps that are necessary for the purposes of maintaining the electoral register. Section 9A of the Representation of the People Act 1983 (RPA 1983) sets out the following steps: sending more than once to any address the form to be used for the canvass making on one or more occasions house-to-house enquiries making contact by such other means as the Electoral Registration Officer thinks appropriate with persons who do not have an entry in the register inspecting any records held by any person which the Electoral Registration Officer is permitted to inspect providing training to persons under their direction or control in connection with the carrying out of the duty 3.24 This standard aims to ensure that properties which have not responded to the annual canvass and where the ERO is not otherwise satisfied that eligible electors are resident will be subject to house-to-house enquiries on one or more occasions. House-to house canvassing is a crucial element in ensuring the registers are as accurate and complete as possible, and will continue to remain a key aspect of ERO activity throughout the transition to IER As part of our assessment of ERO performance against this standard we take into account: the extent of house-to-house enquiries that are carried out what, if any, other methods were used in addition to the steps specified in Section 9A of the RPA 1983 the outcomes of the canvass 3.26 Four EROs reported to us that they would not meet this standard: Mid Devon, Torridge, West Devon and West Somerset. The ERO for West Somerset reported that some house-to-house canvassing does take place in more populated areas, but no house-to-house enquiries are carried out in Mid Devon, Torridge and West Devon As with previous years, the main reasons given by those EROs who reported that they were not meeting the standard for carrying out house-tohouse enquiries were: budget constraints being unable to recruit enough canvassers the rurality of certain local authority areas 3.28 We make clear in our guidance that a lack of resources does not exempt EROs from complying with the law. We recognise the increasing budget 16

19 pressures facing local authorities, which force them to make difficult choices between competing statutory services. But we do not believe that electors should be treated differently solely on the basis of where they live In our guidance we advise that the ERO may decide not to conduct house-to-house enquiries where, for example, there is a potential risk to the personal safety of the canvasser. In these circumstances, however, the ERO should assess the potential for someone personally canvassing each property on a case-by-case basis, and not make blanket decisions on canvassing in particular wards or areas within the local authority. Conducting house-tohouse enquiries at properties in rural areas can be a challenging task; however electors should not be treated differently solely on the basis of where they live and the rural location of a property is not, in itself, sufficient reason to avoid someone personally canvassing the property. In situations where there is an acceptable reason for not canvassing, we would expect the ERO to have an alternative strategy in place for each individual property to reach those residents Despite not conducting full house-to-house enquiries, in our discussions with the four EROs who reported not meeting standard 3, they all told us that they take other measures to follow-up non-responses to canvass forms, including telephone canvassing (and in some cases canvassing, where addresses are available), and checking against other records to see whether electors are still resident and entitled to remain registered. It is important to note that the EROs in question had overall response rates at the 2013 canvass ranging from 92% to 98% (the average response rate in England was approximately 94%) Working with the Cabinet Office Regional Delivery Manager for the South West region, we are continuing to engage with these EROs with a view to ensuring that they have the necessary plans and resources in place to be able to carry out house-to-house enquiries once IER is introduced and then that they are undertaking this work in practice once the transition is under way. Chapter 4 sets out how we will continue to monitor ERO performance ahead of and during the transition to IER Taunton Deane have also told us that they did not carry out a house-tohouse canvass and therefore did not meet standard 3. The ERO for Taunton Deane had planned to carry out a full house-to-house canvass, and this was reflected in their initial return to us in August Their plans were adapted, however, following the sudden death of a key staff member during the canvass and the subsequent merging of electoral services with the neighbouring authority of West Somerset. Taunton Deane carried out a postal 7 Note that the England response rate average is based on incomplete data but is unlikely to change substantially. 17

20 canvass comprising sending an original form and two reminders, and, where they did not receive a response, carried out checks of council tax records to see whether electors were still resident and entitled to remain registered. As at the date of this report, Taunton Deane are yet to confirm their final canvass response rate. We will continue to pursue this information so that we can work with them to understand the impact of their canvassing practices, and will provide an update on this work when we publish the full 2013 canvass data set in May The Commission has been working closely with Taunton Deane and West Somerset to support them in preparing for the transition to IER. They have developed a joint IER implementation plan that demonstrates that they are planning for full house-to-house enquiries to take place We are currently reviewing the data we have received from all other EROs on the conclusion of the last household canvass, and this analysis will help to identify whether EROs did in fact make the necessary house-to-house visits. Where any issues are identified, we will follow up with EROs to establish what happened in practice and why, including what supplementary follow-up activities they undertook with those households that did not receive a personal visit from a canvasser to identify whether electors were still resident and entitled to remain registered. We will publish a summary of our findings when we publish the full 2013 canvass data set in May 2014 and our final assessments of EROs performance against the standards This analysis will also inform our on-going monitoring and provision of support to EROs ahead of the transition to IER, enabling us to identify if there are any further areas where the level of house-to-house enquiries at the last household canvass does not clearly demonstrate that all necessary steps are currently being taken, and to work with any such EROs to ensure that they have the necessary plans and resources in place to be able to carry out house-to-house enquiries once IER is introduced In the event that an ERO does not put in place arrangements to carry out the necessary house-to-house enquiries (or any other important steps to support the transition to IER), while we can intervene to recommend improvements, we do not have the powers to direct EROs to take steps to improve this or any other aspect of their performance. The Secretary of State does, however, have a power of direction over EROs which is exercisable on a recommendation from the Commission. While this power has not been used to date to require action of individual EROs it was used in England (excluding London) and Wales in 2012 to change the timing of the canvass - the option remains available should it be considered necessary to support the effective implementation of IER. Performance standards 6 and 7: Public awareness and Working with partners 3.37 Effective public engagement work was an important element of EROs work around the last household registration canvass, helping to maximise 18

21 canvass response rates, which in turn contributes to ensuring that the register is as accurate and complete as possible. Looking ahead to the transition to IER, engaging with the public will be central to maximising the number of people who are registered individually Our participation standards are designed to ensure that EROs have: considered which of their residents might need additional support or encouragement to register to vote; put practical plans in place to achieve this by working with other council departments or partner organisations where appropriate; and made sure that all of their communications with residents are straightforward and easy to understand In 2012, all EROs met standard 7: working with partners, but 3 EROs - Basildon, Broadland and Horsham - did not meet standard 6: public awareness. We worked closely with those 3 EROs ahead of the 2013 canvass with a view to ensuring that they had a documented public awareness strategy in place ahead of the 2013 delayed canvass Broadland and Horsham provided supporting evidence to us in relation to standard 6 in advance of the 2013 canvass which demonstrated that they had in place a documented public awareness strategy, and we are therefore satisfied that they are now meeting this standard and separately that they also have appropriate local engagement strategies in place for the transition to IER Basildon reported ahead of the 2013 canvass that they were not meeting standard 6 or standard 7. The ERO told us that while they do carry out public awareness activity, this remains undocumented, which means that they cannot meet performance standard 6. Despite meeting standard 7 in 2012, Basildon reported this year that they are not meeting that standard, saying that no activity is undertaken with partners due to demands on electoral services Although we have had detailed discussions about the requirements of standards 6 and 7 with Basildon and encouraged them to improve their performance in this area, they did not produce a written public awareness plan or carry out work with partners at the last household registration canvass, citing the main reason for their approach as being the current economic climate for local authorities, requiring resources to be prioritised accordingly to ensure they are able to deliver their core services We have been clear with EROs in general and with Basildon in particular about the need to have in place a comprehensive public engagement strategy to support a successful transition to IER. As part of our work to monitor EROs preparedness for IER (which is explained in more detail in chapter 4), we reviewed Basildon s public engagement strategy to see whether they were putting in place the necessary plans to engage with residents in their area We are satisfied that Basildon understand that implementing IER depends on effective, targeted public engagement, and their strategy demonstrates that they have carried out work using the data and information 19

22 available to them to identify the key target groups they will need to engage with during the transition to IER, and have identified how they will engage with them. They have also demonstrated that they intend to work with partners within the authority to help them to deliver their engagement activity and maximise its effectiveness. 20

23 4 Performance of EROs: planning for and delivering IER 4.1 EROs will play a critical role in ensuring that the transition to IER is delivered effectively. While the transition will only begin from June, EROs have already been undertaking considerable work in preparation for the change. Since the confirmation dry run (CDR) in summer 2013, EROs have been working to develop their plans for the transition, and they have been supported in this work by the Commission and the Cabinet Office. IER performance standards 4.2 In September 2013, following a period of consultation, we published a new performance standards framework designed to support EROs in planning for and delivering the transition to IER, which reflects what we and the UK Electoral Advisory Board 8 agree that EROs need to do in order to ensure a successful transition to IER The standards were developed around the key challenges facing EROs in the transition, with a focus on what EROs will need to do and know in order to effectively deliver the transition and the information they will need in order to determine whether these challenges are being met. There are two standards: the first covering the planning phase and the second covering the delivery phase. 4.4 The objective of performance standard 1 is to ensure that all EROs have in place a local public engagement strategy which recognises their own specific challenges, taking into account their CDR results, and an implementation plan which sets out how they plan to deliver the transition as a whole. The objective of performance standard 2 is to ensure that EROs deliver their implementation plan, using available data to monitor progress and make amendments where necessary to ensure it remains appropriate. 8 The UK Electoral Advisory Board (EAB) is an advisory group convened by the Electoral Commission consisting of senior Electoral Registration and Returning Officers, and with representation from SOLACE (the Society of Local Authority Chief Executives) and the AEA (the Association of Electoral Administrators). The EAB gives the Commission strategic advice about matters relating to elections, referendums and electoral registration. 9 New performance standards for EROs, September

24 Public engagement strategies and implementation plans 4.5 A key challenge for EROs in the transition to IER will be to encourage residents to take the required action to join or remain on the register, and to ensure that they can vote by post or by proxy, if that is their preferred method. Delivering a successful transition to IER will therefore depend on good local public engagement strategies, designed to support targeted local activity; effective partnership work across and beyond the local authority; and a continued focus on progress and results so that adjustments can be made if necessary. 4.6 Public engagement covers all aspects of the ERO s interaction with their local residents, including: sending forms or letters to individuals or households phone calls, s and direct face-to-face conversations local activity with partner organisations who will help spread the message contact with organisations such as schools, universities, landlords, housing associations and hostels press releases and media work public awareness activity including local advertising and publicity directly aimed at residents 4.7 Each ERO s engagement strategy should identify the particular challenges for their local area and what mechanisms they will use to engage with residents to maximise registration on the IER register. It should cover which groups the ERO needs to engage with, how they will be targeted, how the ERO is going to work with internal and external partners to ensure that they reach people, and how they will evaluate that activity. Engagement strategies will in particular need to address how the ERO will engage with those who are less likely to be confirmed by data-matching and those who are less likely to be currently registered. 4.8 In developing their local public engagement strategy, EROs need to use all available information, including data from the CDR, to understand the key challenges in their local area, and ensure that they put in place appropriate plans to engage residents. This should include: analysis of the CDR results and other available information identification of the different groups of residents and what approaches are appropriate and effective in targeting each of these analysis of what local partners can be used to support the dissemination of messages and how these relationships can be established analysis of what public awareness activities can be used to support direct engagement with residents, including paid for and non-paid for advertising 22