On the 14th of October 2011 I responded to the consultation on a Government White Paper proposing introducing Individual Electoral Registration.

I support individual voter registration, which is what we have outside of the canvass periods now, as I generally think individuals ought be able to control their own voter registration and the supply of their details to the registration authorities.

I had a number of specific concerns with the proposals, my submission was as follows:

• I think that bulk voter registration ought continue in relation to institutional buildings such as student halls of residence. Those managing such institutions ought be asked to supply information of those residing with them after having given individuals the opportunity to opt-out. Arrangements for getting post within institutional accommodation can be unreliable, especially for bulk mailings, as I expect registration forms may be treated. In my experience personally addressed voter cards at election time for example are often left in large piles. I disagree with the Deputy Prime Minister’s contention that a move to individual voter registration could result in a larger proportion of students being registered to vote. I think an increase following the abolition of bulk registration is very unlikely.
• The role of the electoral roll in listing those eligible for jury service does not appear to have been considered in the preparation of this draft legislation. In relation to this point:
  • Students or persons working away from home may have multiple entries on electoral rolls and currently therefore have an increased probability of being called for jury service. The opportunity to correct this ought be taken.
  • The use of the electoral roll for selecting jurors is an important reason for keeping registration compulsory, otherwise people may chose not to appear on the roll to avoid jury service.
• I oppose retaining the household survey and the associated criminal offence of not completing the household survey form. Following a move to individual voter registration I think this form, and offence, ought be abolished. Currently the offence can criminalise individuals who cannot reasonably be expected to know, or find out, information about others living at an address. The household survey form can also require, or enable, someone to give information about an individual to the state when that individual might, quite reasonably, not want that to happen. I think individuals ought be able to control their own voter registration, and the supply of their details to the registration authorities.
• I am concerned that there will be no limitation on circumstances where the electoral registration officer will be able to issue a household form, and no clear restriction on what questions may be asked. I think if the offence is to remain these are significant issues. Officers shouldn’t be able to, for example, send forms on the basis of property’s registration history, or because a property is an a “student area” for example. There should be a specific and personal justification
• I think a system requiring the completion of both individual registration forms, and still retaining household forms, will be confusing and unnecessarily convoluted.
• The current common policy of refusing to accept individual voter registration forms, during the period of a canvas/audit via household forms is confusing and should stop.
• I support sending individual voter registration forms out, and including within them an insert for listing further individuals for whom additional individual forms can be requested.
• An offence which very large numbers of people are committing makes a mockery of the law and if some but not all face prosecution that opens up the risk of selective persecution on grounds unrelated to the offence. Care should be taken to avoid a situation where large numbers of people become criminalised through oversight, misunderstanding, or simply not being aware of electoral registration requirements. Every opportunity must be given to help individuals register, or show that they are in-fact registered, before any prosecutions are commenced. I think any offence should not be directly and primarily related to the non-completion of forms.
• While I note the draft legislation is designed to enable the use of online and telephone registration I would suggest going further and requiring registration officers to allow online registration.
• My local registration officer has sent out household surveys containing information as on the current register with the exception of the status of the opt-out from the commercially available version of the electoral roll, which was re-set removing previous opt-out indicators. I suggest that the legislation ought require such opt-outs to be enduring until/unless actively reversed by the individual concerned.
• Procedures and practices for removing individuals from the electoral roll ought be made clear. Electors who are already on the electoral roll should be accurately told what, if anything, will happen to their registration if they are not included on household survey forms, or individual voter registration forms.
• Where electoral registration forms contain statements such as “the law says you must complete this form”, a reference to the law being referred to ought be required to be included.
• It is very common for people who are named on council tax bills to assume they are registered to vote. Contrary to the view of the UK establishment this is not an utterly absurd thing to assume. I therefore suggest that when opening a new account for council tax purposes councils ought be required to work with electoral registration officers to add relevant individuals to the electoral roll.

Government Response

In February 2012 the Government published its response to the public consultation. The changes highlighted by the Government in their email to those who responded to the consultation were:

• The government is now planning to match the names and addresses of all individuals currently on an electoral register against the data held by public bodies such as the DWP and local authorities. If an elector’s information can be matched, the individual will be automatically placed onto the new IER register.
• The government is reconsidering an individual’s ability to opt out – looking to either tighten this provision or remove it altogether
• The proposal is now to reschedule the autumn 2013 canvass to spring 2014

In addition:

• It will remain an offence to provide false information to, or not to respond when required to provide information to an Electoral Registration Officer e.g. an annual canvass form.
• The government has rejected their idea of creating a new criminal offence, but is considering a civil penalty for non-response to an invitation to register.This is good, but in practice the difference between a criminal offence and a civil penalty will be largely academic.
• The government is considering making opting out possible, but difficult. My view is this is a bizarre stance to take; if the government offers something it ought be easy, and online. Offering an opt out, but only if you turn up in person at the offices of your local council during working hours is crazy.

As for addressing any of the concerns I, and no doubt others, raised:

• On jury service, the government have stated: “we would look to ensure that those recorded as opting out of registration continued to be eligible to carry out jury service.” This is of course excellent, it was surprising this was looked-over in the original proposal.
• There is a non-response on the issue of registration of students in halls of residents. The government has responded, but their response doesn’t say anything: “We acknowledge these concerns and are currently working with organisations representing these groups to establish ways that the registration process and the transition for these groups can be as simple and accessible as possible.”
• My other suggestions were ignored.

I was one of 806 members of the public to submit a response to the consultation.

What Next

• Legislation is during 2012 and Individual Voter Registration would be carried out during 2014 prior to a 2015 general election.

Given the number of points where the Government is still undecided, it may be that MPs will be left with a lot of work to do when the legislation is put in front of them.