Delivering the annual canvass - Scotland
The following guidance has been produced to support Electoral Registration Officers (EROs) in planning for and delivering the annual canvass.
It has been developed in close consultation with colleagues across the electoral community including the Department for Levelling Up, Housing and Communities, the Association of Electoral Administrators (AEA), the Scottish Assessors Association (SAA), the Elections, Registration and Referendums Working Group (ERRWG) and the Welsh Electoral Practitioners Working Group (WEPWG).
The guidance is directed towards the ERO and the duties they carry out. As these duties may, in practice, be carried out by deputies and/or appointed staff, we use the term ‘you’ throughout this guidance to mean the ERO and whoever is carrying out the ERO’s functions on their behalf.
Throughout this guidance we use ‘must’ to refer to a specific legal requirement and ‘may / should’ for recommended practice.
The guidance has been produced based on, and should be read in accordance with, the requirements set out in section 9D of the Representation of the People Act 1983 and in the Representation of the People (Scotland) Regulations 2001.
The endnotes in this guidance refer to the relevant provisions that have been amended by The Representation of the People (Annual Canvass) (Amendment) Regulations 2019, The Representation of the People (Annual Canvass) Amendment (Scotland) Order 2020 and The Representation of the People (Annual Canvass) (Miscellaneous Amendments) (Scotland) Regulations 2020.
To help you use this guidance we have produced a Q&A document that should answer any initial queries you may have.
Updates to our guidance
Date of update | Description of change |
---|---|
February 2023 | Updates to the requirement to Notify anonymous electors with Anonymous Elector's Documents about a replacement document |
Developing plans for the annual canvass
Developing plans for the annual canvass
This section contains guidance on how to develop your plans for the annual canvass. It covers project planning and risk management as well as some considerations for planning the delivery of specific processes.
What is the annual canvass?
The annual canvass requires you to contact all residential addresses in your area to help you establish if the information you currently hold on the electoral register is complete and accurate.
There is a legal framework that sets out the statutory requirements of the annual canvass. Within this framework you, as Electoral Registration Officer (ERO), will need to make a number of decisions, helping you to determine the most appropriate approach to the canvass within your area each year.
Delivering the annual canvass: what are my duties as ERO?
Delivering the annual canvass: what are my duties as ERO?
Part of your statutory duties as ERO includes the delivery of an annual canvass. As part of this, you must:
- disclose data to the Ministry of Housing, Communities and Local Government as part of a national data matching exercise known as the national data match step1 (and, in addition, you also have the discretion to carry out local data matching)
- take into account the results of national data matching when making a decision on the allocation of properties to canvass routes
- carry out the required statutory steps for properties allocated to each canvass route
- provide training, where necessary, to staff who will deliver the canvass on your behalf
- publish the revised version of the register by 1 December (except for where an election is held between 1 July and 1 December, in which case the publication of the register can be delayed until up to 1 February the following year)2
- provide statistical information about your revised register to the Secretary of State as required, for example the number of parliamentary and local electors you have registered by constituency.3
As ERO, you are also a data controller and have a statutory responsibility under data protection legislation to ensure that personal data is kept securely. Any breach could constitute an offence and could result in a loss of confidence in the electoral registration process.
- 1. Regulation 32ZBB, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Section 13(1)(a) of RPA 1983 ↩ Back to content at footnote 2
- 3. Regulation 44, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
What should be included in my project plan for the annual canvass?
Project plans and risk registers are vital in helping to support the effective delivery of the annual canvass.
We have developed a template registration plan that you might find helpful.
To inform these, you will need to make some key decisions which will help you map out how you will deliver the whole canvass process. These should include:
- when your canvass will begin
- when and how you will identify any properties you want to canvass via Route 3 – the defined property route, including how you will identify the responsible person for those properties and when you will contact them
- when you plan to undertake the national data match step
- whether to carry out local data matching and, if so, when you will do so
- a review of the size of your canvass areas to ensure they are suitable to support your plan for canvass delivery and follow up
- how and when you will allocate properties to canvass routes
- what type of communication methods you will use for each route
- what response mechanisms you will make available for the canvass and how you will ensure they are set-up in advance
- the timescales for sending your canvass communications for all routes
- how you will follow up with any non-responders (where required)
- when, and on what basis, canvassers will be recruited and paid
- what contingency arrangements you will need should an election take place during your canvass, including how you will redeploy resources to target registration in those areas where the election is taking place
- when and how you will publish your revised register
Once you have established your high level plan you can start to plan the specific detail of the canvass process.
You will need to identify the activities you need to carry out to deliver your high level plan, and capture these and the timescales for their delivery. Some of the key activities you will need to ensure are covered in your plan are outlined on the following pages.
Preparing for data matching
Preparing for data matching
- preparing your register for data matching, ensuring that it is as up to date as possible to help increase the number of successful matches returned as part of your results
- booking the date for your national data match and confirming when it will take place and when the results will be received
- establishing which individuals or groups of data will be excluded from the data match (for example, special category electors)
- preparing for any local data matching, including identifying what data sets you will use and when you will carry out the matching for each of these sets
- establishing when and how you will analyse all data matching results and determine which canvass route households will be allocated to
- ensuring flexibility in your plans, when and how you will revise them if the outcomes of data matching are not as you expected
- preparing an audit trail of any actions and decisions taken which relate to changing a route allocation from one route to another based on data matching results
Staffing and resources
Staffing and resources
- checking your resource assumptions and ensuring that sufficient funding will be available
- ensuring the availability of support staff from across the organisation, such as IT and frontline/call centre staff
- reviewing your staffing structure to identify if current staffing levels remain sufficient
- developing a staff training schedule, to include data protection considerations, for the different types of staff involved in the canvass
- ensuring any storage requirements are sufficient, both for printed forms and scanned forms, and that you are not retaining personal data for longer than is necessary
- establishing how and when you will promote and communicate key canvass messages
- briefing your media and communications teams about the key messages and dates and establishing how you will use your local authority website, press releases and social media platforms to encourage responses
IT and suppliers
IT and suppliers
- reviewing any supplier arrangements that are in place and considering what, if anything, may need to be revised; and, if necessary, liaising with your procurement team to ensure that any procurement complies with legislation
- engaging with your chosen printer to agree written contracts and establish timescales
- deciding on and making arrangements for any automated response mechanisms you will offer (for example, telephone and online response channels)
- scheduling the proofing of materials and detailing when any data is due to be sent or received
- reviewing your IT arrangements, including checking your scanners and other hardware is in good working order
Data protection considerations
- engaging with your Data Protection Officer regarding your plans for delivery of the canvass
- reviewing your document retention policy and any privacy notices in line with data protection legislation
- developing any necessary data sharing agreements
- ensuring written contracts are in place with contractors or suppliers
What plans should I put in place to evaluate the success of canvass activities?
Your project plan should also detail how you will monitor the effectiveness of the decisions you make and the activities you undertake to enable you to evaluate the impact of your actions. This should help you to refine your approach for the current canvass, wherever possible, and should also inform your plans for future canvasses.
The performance standards for EROs, and the tools and templates available to support them, will assist you in understanding the impact of your activities, help identify where improvements can be made and support you to report on your own performance locally.
You should use the data and qualitative information set out in the standards to help understand the impact of your activities to identify what works and what doesn’t and where improvements can be made. The framework is designed to support this analysis and focuses on the key data and information that will indicate what is working well and what is not working so well.
The standards, and the supporting tools and templates, should also help you to demonstrate locally – whether within your local authority, to elected members, or more broadly – how the activities you are carrying out contribute to the provision of an efficient and effective electoral registration service and, ultimately, will help to ensure that everyone who is eligible and wants to vote is able to do so.
How can I manage risks to the annual canvass?
When planning for and delivering your annual canvass you will need to consider the risks to the canvass and how you will mitigate these, ensuring that these are captured in a risk register. This risk register should be kept under regular review and you should use it to:
- record any risks identified, including the seriousness of any risk by indicating both the likelihood of the risk occurring and the impact of the risk if it did occur
- monitor and document any changes to these risks
- record actions identified to mitigate the risks
- monitor and record how mitigating actions are being taken forward
We have developed a template risk register that you might find helpful. The template provides some example risks and suggested actions for mitigating those risks.
In addition to the risks identified in the template you should also identify any other risks, including ones specific to your local circumstances, and how you would mitigate those.
Planning for canvassing Route 3 properties
The identification of potential Route 3 properties should take place at an early stage in your planning.
This section contains guidance on how to identify Route 3 properties and how and when to identify and make contact with a responsible person for each property.
What are Route 3 properties and how can I identify them?
Route 3 – the defined property route, involves collecting the information required for the canvass for specified types of properties from a responsible person, where one can be identified.
Using Route 3 could be more effective and efficient in getting accurate and complete responses for properties with multiple residents than canvassing using an alternative route.
The identification of potential Route 3 properties and the responsible person for those properties should take place early in your planning for the annual canvass as this will have an impact on the allocation of properties to different routes.
If you are not able to identify and make contact with a responsible person for a property before finalising your allocation of properties to canvass routes, you will be unable to proceed with canvassing that property via Route 3.
Which properties can be canvassed using Route 3?
The properties that can be canvassed via Route 3 (the defined property route) are defined in legislation as:1
- Registered residential care homes
- Houses of multiple occupation
- Student accommodation: for example, student halls of residence
- Hostels
To be canvassed by Route 3, a property must also be either a property at which persons reside who together do not form a single household2 or a property where you have attempted to deliver a document in the previous 18 months but have been unable to do so.3
In addition, to be able to allocate a property to Route 3 you must believe you are more likely to get a response using Route 3 than via an alternative canvass route,4 and you must have been able to identify a responsible person to provide the information required for the canvass.
Accessing other local authority records or reviewing information from the previous canvass could help you to identify other properties in your database that may meet the criteria to be canvassed via Route 3.
You will need to be satisfied that the criteria specified in the legislation is met for any other property you choose to canvass under Route 3.
Which properties cannot be canvassed using Route 3?
The legislation specifically provides that Route 3 cannot be used for ordinary blocks of flats,5 which should be able to be effectively canvassed via Route 1 or Route 2 as appropriate based on the results of data matching.
In addition, where information you hold shows that the property is only occupied by persons under the age of 18 you cannot use Route 3 to canvass the property: in such cases, you must use Route 2 – the unmatched property route.6
Also, properties where all registered individuals are a category of elector that must be excluded from the national data match step, such as anonymous electors, are not eligible to be canvassed via Route 3.
- 1. Regulation 32ZBF(2), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBF(2)(f), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
- 3. Regulation 32ZBF(2)(f), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
- 4. Regulation 32ZBF(2)(f), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 4
- 5. Regulation 32ZBF(3), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 5
- 6. Regulation 32ZBA(6), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 6
Who is the responsible person for a Route 3 property and what information can they supply?
A responsible person is defined as being any person who lawfully holds or has access to and may lawfully disclose information to the ERO in respect of each person who is residing at a property and is eligible to be registered.1
Data provided by the responsible person will help you to establish who is and is not resident at a property, but cannot be used for any form of block registration: you will need to carry out the appropriate registration activity – such as starting the ITR or review process – based on the data provided to you.
You will need to ensure that the information you hold on responsible persons for Route 3 properties is reviewed regularly. You should ensure that the information is up to date and that the details of anyone who is no longer associated with a property are removed.
- 1. Regulation 32ZBF(8) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
When and how should I contact the responsible person for Route 3 properties?
You will need to establish contact with those individuals who you think may be suitable to act as the responsible person for a Route 3 property. You should make your initial contact as soon as possible in the planning stage of your canvass; only once you have identified and confirmed a responsible person for a property can you allocate it to Route 3.
As there are no prescribed contact methods under Route 3, you will need to consider the most appropriate way to make initial contact with these individuals.
The purpose of the contact at this point is:
- to establish whether the identified individual is able to act as the responsible person1
- to provide an explanation of the role and responsibilities of a responsible person
- to communicate your statutory right to request information from a responsible person about the residents in a property
- to communicate the responsible person’s requirement to respond to your request
- to establish the communication methods that will be used going forward
- to identify an alternative individual as a responsible person for the property if the person you have contacted is not able to comply with your request
You should ensure that you record the steps you have taken to make contact with these individuals and to confirm that they are able to provide you with the information required by the canvass.
You will also need to consider the best method of communication for Route 3 properties, based on the property type and the contact information you hold for the responsible person.
Whilst you will need to identify and make initial contact with the responsible person at Route 3 properties at an early stage in your planning, you may decide to canvass different Route 3 properties at different times. For example, you may decide to ask the responsible person for student accommodation for the information required for the canvass shortly before term-time begins, rather than at an earlier stage of your canvass.
- 1. Regulation 32ZBF(8), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Is a data sharing agreement required for Route 3 properties?
You will need to decide if data sharing agreements are necessary with any of the responsible persons for Route 3 properties you have identified in your area.
The information you receive from the responsible person will contain personal data, which is being shared between two data controllers. Whilst data protection legislation does not require a written agreement when sharing data between data controllers, it is nevertheless good practice to have a data sharing agreement in place.
Having a data sharing agreement in place with the responsible person will demonstrate that you are both acting in accordance with data protection legislation and will help to avoid any liability implications of one party being seen as a controller and the other being seen as a processor.
Our guidance on data protection for EROs and ROs provides information in relation to your role as data controller and a checklist to help inform the content of data sharing agreements.
Planning for data matching
Data matching is an integral part of the new canvass and you will need to plan how and when you will carry this out.
This section contains guidance on the things you will need to consider when planning for national and local data matching.
What do I need to consider when planning for the national data match step?
The national data match step involves the checking of information about existing electors on your register, against data held by the Department for Work and Pensions (DWP).
By default all properties start allocated to Route 2 – the unmatched property route.
The results of the national data match, along with any local data matching you have undertaken, will help you determine whether the property as a whole is matched or unmatched and you must use this information to help you to allocate that property to the appropriate canvass route.1
Once allocated to the appropriate canvass route, you can determine which type of contact to make in relation to each property during the canvass.
- 1. Regulation 32ZBA(2), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What action should I take to prepare my register for the national data match step?
Whilst it is important to ensure you have processes in place to maintain your register throughout the year, carrying out additional register maintenance ahead of the national data match step should help to ensure that the information you provide is as accurate and complete as possible.
This should then help to ensure more accurate results, which in turn can help you to maximise the efficiency of your canvass and make best use of your available resources.
This preparatory work should include the following steps:
Ensure that any outstanding activity is up to date
- You should, wherever possible, conclude reviews and determine any deletions needed as a result of these prior to the national data match step.
- You should ensure that any other required deletions are determined prior to the national data match step.
- You should follow up on any outstanding queries, exceptions and attestations to ensure as many electors can be added to your register as possible.
- You should check any individuals held in your system as potential electors in properties against other records, or identify any new potential electors that should be added to properties. Potential electors are not registered electors but are individuals who are recorded in your EMS, likely as a result of local data mining or a returned canvass form, who may be eligible but have not yet registered to vote at the address. This information is useful because it may indicate that there are changes required to the register for that property, with individuals potentially being resident who have not yet made a successful application to register. Potential electors at an address may also be indicative of the need to capture additional changes for those individuals who are currently registered at the property.
Ensure that your property database is up-to-date
- You should ensure that each address has a unique property reference number (UPRN). If not, you should liaise with the Corporate Address Gazetteer (CAG) team to ensure that UPRNs are attached to each property.
- You should review any records you hold that will help you to identify certain types of properties and if possible make sure these are reflected in your system – for example, identifying that a property is a care home, house in multiple occupation (HMO) or student accommodation may have an impact on the route you may choose to allocate the property to.
- You should check whether the information you hold for empty and void properties is up to date. You should identify which local data sources are available to you that will contain the information you need to do this and update your records accordingly.
How should I decide when to carry out the national data match step?
The national data match will need to take place before you begin your canvass activity. The Ministry of Housing, Communities and Local Government intend that the service will be open from 1 June until end of August, and will provide a booking tool to allow you to choose your preferred date for your data match. If this date is not available, you will need to choose another.
To help you decide when you want to conduct the national data match step you should consider guidance from the Ministry of Housing, Communities and Local Government on the timeframes for booking and conducting the national data match step.
In order to identify the most appropriate date for your national data match you will need to have considered timings for undertaking your additional preparatory work on the register as this should be carried out before you send your data.
As the national data match will need to take place before you begin your canvass you will also need to think about when you want to begin your canvass and ensure that your canvass activities are scheduled for after data match has taken place.
Once your national data match date is confirmed and you know which date you are working towards, you will need to revisit your canvass plans to make sure they are still workable, making any adjustments that you identify as necessary. This may include revising the dates on which you plan to start sending canvass communications for each of the three canvass routes.
What do I need to consider when planning for local data matching?
As well as carrying out the mandatory national data match step, you have discretion to match all, or part, of your electoral register against locally held data sets (such as council tax or housing benefit data).1 This can take place before or after the national data match step, or both before and after the national data match.
The outcome of the national data match along with any local data matching you have undertaken will influence the allocation of properties to canvass routes and determine which type of contact you are required to make in relation to each property during the canvass as a result.
Working with other council departments
Working closely with other council departments may help you to work more effectively and efficiently with local data. If a consistent approach to data collection can be agreed with other departments, it will be easier to use multiple data sets for your own purposes.
When receiving local data sets from other teams or departments, you should consult with your EMS supplier to check how the data should be formatted. You may find that significant time and resources are required to properly prepare the data before it is suitable to be imported into your EMS system.
Other departments within your council may have more experience with manipulating data effectively. You should consider working with these departments, and potentially seconding skilled colleagues if possible, to assist you with ensuring your local data is ready to upload to your EMS in a timely manner.
When setting up a new working relationship for the sharing of local data, you may want to have an initial telephone conversation or face to face meeting to discuss your aims and agree working arrangements. Some of the points it may be useful to cover in your initial contact include:
- outlining the legislative requirements of the canvass, and your rights to access data
- explaining the benefits that can be gained by the increased use of data matching
- discussing the level of support that can be offered to you and your team
- agreeing a shared approach to working with data, potentially through the use of a data sharing agreement
- establishing a clear timeline for your work together
- agreeing how you will communicate going forward
- agreeing an approach to evaluation of your work together at the end of the canvass
- consideration of whether any council or service privacy notices should be updated
You are not automatically entitled to access and use any additional contact information contained in local records other than names and addresses. Further information on the collection and sharing of other contact details such as email addresses and telephone numbers can be found in our guidance on planning for canvass communications.
Establishing partnerships and setting out plans for both the sharing and processing of local data may initially take some time and effort, but should become less intensive in subsequent years as working practices and relationships are embedded.
As people become familiar with their roles in the process, what data they need to provide and what is expected of them, you should see improved results and a more efficient, streamlined process.
- 1. Regulation 32ZBA(8) The Representation of the People (Scotland) Regulations ↩ Back to content at footnote 1
What is local data?
Local data is any set of data which is collected by another body, or by any local authority, including your own.
Examples of local data open to you include:
- council tax data
- adult social care data
- local authority billing and payments data
- parking permits data
- school, college and university admission data
- blue badge data
- customer service records
- payroll data
- registrars data
- housing benefits and rent data
- green/garden waste subscription data
- council-run facility membership data (for example, libraries or gyms)
Other sources of information, such as personally knowing someone or word-of-mouth, are not considered to be sources of local data.
Your powers to request local data
As ERO, you are legally entitled to access local data sets and to inspect and make copies of records kept in whatever form by:1
- the council which appointed you
- any registrar of births, deaths and marriages
- any person, including a company or organisation, providing services to, or authorised to exercise any function of, the council; this includes those that are providing outsourced services under any finance agreement
There are no statutory or other restrictions, including data protection legislation, that can be used to refuse disclosure of such information to the ERO.2 You are also legally entitled to require any other person to give you information required for the purposes of maintaining the electoral register.3 EROs are able to access such data in line with data protection provisions as there is a lawful basis for its processing; the performance of a public task in the public interest.
In the event that any person does not co-operate with your request it may be appropriate to point out that there is the potential of a criminal penalty of a fine up to a maximum £1,000 for failing to provide the information required.
You may also wish to discuss with your Data Protection Officer whether a Data Sharing Agreement could facilitate access to local data.
Our data protection guidance for EROs and ROs provides guidance in relation to your role as data controller and a checklist to help inform the content of data sharing agreements.
- 1. Regulation 32ZBA(8) The Representation of the People (Scotland) Regulations ↩ Back to content at footnote 1
- 2. Schedule 2, paragraph 1(5) of the RPA 1983 ↩ Back to content at footnote 2
- 3. Regulation 23, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
How should I select my local data sources?
As a minimum, each local data set should include:
- First name
- Surname
- Postal address
Data sets which also include the following fields may help to improve the quality of the match results:
- Middle name(s)
- UPRN data
- Date of birth
- Previous names
- Age of data, for example when it was created or last updated
Local data sets do not have to include data for all properties on your register and could be more focussed on specific property types or groups of individuals.
For example, you may have data from social services or education departments which may only cover some of your electorate, but which may still be useful.
How do I ensure a data source is of high quality?
You should ensure that you only select data sources that are high quality. A high quality data set is one where the information within it is reliable, trusted, current and accurate. The Ministry of Housing, Communities and Local Government have a resource available on how to assess the quality of local data which can be found below:
You should also consider what data standards and good practices exist in relation to the local data sources you wish to use and whether the data holder follows them.
For example, the Department for Work and Pensions has set out detailed guidance on good practice for the processing and use of council tax benefit and housing benefit data, which includes guidance on the checking of evidence provided to local authorities and how to deal with fraud. An ERO for an area that delivers its benefits service to these standards should be able to be confident in using benefits data for local data matching.
When determining the quality of a local data source you should take into account when it was last updated and whether the source(s) of the data are reliant on information provided by individuals with no checks by the local authority on the accuracy of the information.
For example, applications for library membership may be based entirely on information provided by the service users and so you may conclude that, as a result, library data is not suitable for local data matching.
In addition to being able to trust that the local data source is of high quality. You also need to consider any cost implications associated with processing local data and, if there are any costs, whether they make the best use of the resources you have available to you.
For example:
- Will work need to be carried out manually by you and your staff to ensure the data is useable or will you need support for the data matching from another team, such as from IT, to manipulate the files?
- Can the data file be managed by a partially automated process by loading it into your EMS system or similar?
- Will you need to purchase any new or additional software or licenses for any existing software?
You should test new local data sets before you use them. You should talk to your EMS provider about how your EMS system may help you to do this in practice.
You should evaluate the effectiveness of your local data sets each year using the data accuracy scores provided by the Ministry of Housing, Communities and Local Government. These scores will provide an indication of how effective the different local data sources have been in matching electors. This will enable you to make more informed decisions about using local data sets in future canvasses.
When can I carry out local data matching and how long will it take?
If you have decided to undertake any type of local data matching you will need to decide when it will take place. Local data matching can be helpful when undertaken either before or after the national data match step, or indeed at both stages.
Your decision around the timing of any local data matching may depend on:
- when the data can be provided to you and when you plan to use it, for example the most up to date student data is likely to be available at the beginning of the academic year
- how recent the data is; local data will be most accurate and useful for data matching if it has been recently updated
- the size of the data set and whether you are carrying out a partial or full register match; this may have an impact on the amount of time you have to analyse the results before allocation of properties to canvass routes
- the format in which the data is held and whether it will need to be processed before you can use it
Carrying out local data matching before the national data match step may allow you more time to analyse your local data matching results.
Alternatively, carrying out checks of data that is regularly updated locally, such as council tax data, after the national data match step and as close as practicable to making your decision on the allocation of properties to canvass routes may improve the quality of your data match results, enabling you to allocate more properties to the most appropriate route.
Checking empty and void properties as part of local data matching
Local data matching could include a check of the information you hold on empty or void properties. If you are going to compare empty and void properties against local data sources such as council tax records, your plan should reflect this and make provision for when and how you will carry it out.
Empty and void properties are not exempt from the annual canvass but they are automatically excluded from the national data match step. This is because there are no individual elector details to match against DWP records.
If your local data matching can’t confirm properties as empty or void, they will need to be canvassed via Route 2 – the unmatched property route. If you are able to confirm that properties remain empty or void, they can be allocated to Route 1 – the matched property route.
It is important to remember that once a property has been assigned to a route, you must take all the necessary steps before closing the chase cycle. You cannot use local data to close a chase cycle.
Are data sharing agreements required when I access local data?
Where you request to inspect and/or take copies of data, the holder of the data cannot use a statutory or other restriction, including data protection legislation, to refuse the disclosure of data to you.1
Whether you carry out local data matching yourself, or outsource local data matching, the information you receive will contain personal data which is being shared between two data controllers.
Whilst UK data protection legislation does not require a written agreement when sharing data between data controllers, it is good practice to have a data sharing agreement in place.
Such agreements demonstrate that all parties are acting in accordance with data protection legislation and will help to avoid any liability implications of one party being seen as a controller and the other being seen as a processor.
Do I need a data sharing agreement when using data held by a local authority?
Where you are receiving information from the council(s), that you are ERO for to
- ascertain the names and addresses of people who are not registered but who are entitled to be registered, or
- identify those people who are registered but who are not entitled to be registered
a written agreement between you and the council(s) regulating the processing of the information should be in place and this agreement should include details about data transfer, storage, destruction and security arrangements.
Our data protection guidance for EROs and ROs provides guidance in relation to your role as data controller and a checklist to help inform the content of data sharing agreements.
- 1. Regulation 23, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Planning for canvass communications
You will need to carefully plan how you will deliver your canvass communications.
This section contains guidance on the things you will need to consider when planning your canvass communications and on the response mechanisms you will make available for electors.
What do I need to consider when planning my canvass communications?
Before planning the canvass communication channels to use, you will need to have read the guidance for each of the canvass routes; Route 1, Route 2 and Route 3 so that you have an understanding of the communication types and contact requirements for each route.
As part of your planning you will then need to decide which communication channels you will use for each contact stage in each of the routes. Some of the key considerations for each communication channel are outlined on the following pages.
You should also take into account that legislation requires you to undertake follow-up activity within a reasonable period of time. A reasonable period of time is not defined in legislation. In our view it should be no longer than 28 days and may, in some circumstances, be shorter, for example, where you are approaching the conclusion of the canvass or where there is an election due to take place.
How can I collect email addresses and phone numbers?
How can I collect email addresses and phone numbers?
You can collect email addresses and phone numbers directly from householders and electors, and you may be able to access them through inspecting local records.
You should look for opportunities to collect email addresses and phone numbers from canvass communications and other electoral correspondence throughout the year, such as voter registration forms and absent vote applications.
You should capture as many email addresses and phone numbers as possible during the canvass alongside your other actions when processing canvass responses.
Whenever you collect email addresses and phone numbers from electors, you should ensure that it is clear to them that the provision of these is optional, and you should set out how you will process and use the information in your privacy statement.
Can I collect email addresses and phone numbers from other local records?
You are legally entitled to inspect and make copies of local records such as Council Tax and customer service records, for the purposes of your registration duties.1
Relevant councils are expressly permitted to disclose information contained in local records to enable you to ascertain the names and addresses of people who are not registered but who are entitled to be registered.2
2
We have produced further guidance on the records you can inspect to identify new electors, including what you can use the information for, and advice on whether data sharing agreements are needed between the council and the ERO.
However, you are not automatically entitled to access and use any additional contact information contained in local records other than names and addresses. To access and use additional contact information, such as email addresses and phone numbers from local records you will require:
- a data sharing agreement to be in place between the council and the ERO, and
- the council to have informed individuals about the potential sharing of such information through their privacy notice
You will therefore need to engage with relevant council departments, holding constructive conversations with them and your data protection officer, to gain support for your approach to using e-communications. This could be tied in with your wider conversations about accessing local data for the purposes of your registration duties such as local data matching.
You should work with council departments and the data protection officer to develop data sharing agreements and to identify privacy notices which will need to be updated, so that when contact details such as email addresses and phone numbers are collected, the necessary consent is given for these details to be disclosed to the ERO.
Our data protection guidance for EROs and ROs provides further information on data protection considerations.
What if the council uses a customer records index?
Some councils have adopted a customer records or citizen index, to keep customer records in one central database. Such records are collated from a range of customer contact information and are likely to be up to date and accurate.
As the data in such databases is collated from sources across the council it is likely that data sharing agreements and privacy notices will already be in place for maintaining their customer records index which may only need minor changes to allow for the disclosure of additional contact details to the ERO. You should contact your DPO to understand what you may need to do locally.
Checking the accuracy of the information you collect
In order to reduce the number of emails or text messages that go undelivered due to errors in phone numbers or email addresses, you should carry out quality checks on the contact information you have collected. You could export the data into a spreadsheet to assist with this, or see if your EMS system can produce reports which could help to highlight inaccuracies in your data.
You should check for obvious errors such as domain names in emails being misspelt, incorrect use of punctuation or spaces in email addresses, and phone numbers with missing digits. You could then cross reference scanned images or paper applications to check and correct any contact details that contain errors.
Ensuring that the contact details you hold are up to date and accurate will increase the number of messages delivered correctly and will reduce the administrative burden of dealing with email bounce backs when processing. For more information on managing bounce backs, please see responses to Route 1 e-communications.
- 1. Regulation 35, Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 35A, Representation of the People (Scotland) Regulations 2001↩ Back to content at footnote 2 a b
Using electronic communications
Using electronic communications
Where you decide to use e-communications, you will need to identify the steps needed to set these up and reflect these in your plans.
You will need to decide whether to manage e-communications in house or via an external provider, and you may decide to take different approaches for different types of e-communication.
For example, you may choose to send emails yourself and outsource SMS messaging to an external provider. Any person who will be processing personal data for use with any e-communication channels must comply with the requirements of data protection legislation.
You will need to create template communications in advance where you are using emails, SMS, or other written electronic communications.
Our guidance for Route 1 and Route 2 contains detail of what information must be included and captured in e-communications and we have produced template emails that can act as a basis for your e-communications.
You will also need to ensure that you have mechanisms in place to track and monitor the dispatch of e-communications to ensure that you have an audit trail of all contact attempts with properties and electors throughout the canvass.
Monitoring the success of contact attempts using different contact methods will help you to evaluate their effectiveness and refine your approach as needed for future canvasses. The data set out in the performance standards for EROs will also help you to understand the impact of your activities and where improvements can be made.
Ensuring public confidence when using e-communications
Ensuring public confidence when using e-communications
It is important that recipients of your e-communications trust them and have confidence that they are legitimate, so that they pay attention to the information provided and respond and take necessary action as needed.
Some residents may not be used to being contacted by the ERO or the council through e-communications, so you should think about how you can prepare them for being contacted this way, for example through press releases and social media messages. We have produced canvass resources to support you with public engagement, including social media templates which can be used in the run-up and throughout the canvass to raise awareness. You should also work with the communications team in your council to raise awareness about the canvass.
As well as using e-communications during the canvass, you could consider the benefits of contacting electors through these methods outside the canvass period, for example in the run up to an election.
To help increase confidence that emails are official you should ensure that recipients can clearly identify that they are from you by including your council name in the subject line and your logo in the body of the text. If you are using a generic outbox to send emails, you could also personalise the message to include the householder’s name in the greeting.
You should proactively inform recipients that you are contacting them because you hold their information on your electoral register database so that they can be confident that their data has been used legitimately. Even if you are encouraging residents to reply using an automated response method, you should include dedicated contact details for queries, as well as a link to your website with details of your privacy notice and how recipients can opt out of further e-communications, in order to promote confidence in the legitimacy of the communication and meet all data protection requirements.
We have produced an email canvass communication template to support you when contacting householders by email. The email template can be used for either Route 1 or Route 2 communications. The email template is not prescribed, however we recommend that you use it because it has been tested with the public.
Further guidance on the content of your e-communications is given in what information should an e-communication contain?
Managing messages and responses
Managing messages and responses
As set out in using electronic communications you will need to ensure that you have resources and systems in place for sending e-communications and for tracking and monitoring responses.
If you are managing this in-house, you will need to liaise with your IT department to discuss how they can support you, which could include:
- setting up a generic mailbox, with sufficient capacity to deal with your estimated volume of likely responses based on previous years and/or the number of emails you plan to send as part of your canvass
- the proposed timescales for sending your communications, so that any additional help desk support can be factored in
- any additional opportunities to check your data before sending your communications
- whether to send messages in batches
- advice on how to avoid e-communications being treated as ‘spam’ or ‘junk’
- how to track and monitor responses, including the management of bounce backs (guidance on the processing of bounce backs can be found in responses to Route 1 e-communications.)
Using external providers and messaging platforms
You could decide to use an external provider or a messaging platform to send e-communications to residents, both during and outside the canvass period. This may involve providing the contact details you hold for residents to a provider who will send the messages on your behalf. You will need to be satisfied that the provider complies with data protection legislation when processing data. Some messaging platforms, such as the UK Government’s ‘Notify’ service, can be integrated with your EMS system, which would enable you to monitor responses through your existing software.
The following case study describes how this has been utilised in Tower Hamlets:
Contacting electors by telephone
Contacting electors by telephone
If you are contacting electors via telephone you will need to decide whether to manage these calls in house or via an external provider. You will also need to plan in advance the scripts your staff or external providers will use for their conversations. We have provided a template script for use by staff contacting electors by telephone.
It may also be useful to provide a list of possible FAQs and suggested responses for your call handlers based on your approach to the canvass in your area.
You will also need to ensure that you have mechanisms in place to track and monitor the placing of phone calls, to ensure that you have an audit trail of all contact attempts with properties and electors throughout the canvass. Monitoring the success of contact attempts using different contact methods will help you to evaluate their effectiveness and refine your approach as needed for future canvasses.
Using printed communications
You will need to decide whether to use an in-house or an external printer to print your canvass communications. Whoever you use, you should be satisfied they will be able to cope with the complexity and volume of printed material to be produced.
You should ensure that data protection principles are met in any contract tender exercise, and document your decision-making process. Whenever you use a processor, data protection legislation imposes a legal obligation to formalise the working relationship with them.
Whether you are using an in-house or external printer, you must have a written agreement or contract in place. This will help to ensure that the requirements of data protection legislation will be met, including the requirements relating to appointing a processor.
Following the national data matching step, and any local data matching, you will have allocated all of your properties to the appropriate canvass routes, made decisions about which communication channels you plan to use for canvass communications at each stage and how you will manage their distribution.
You will then be in a position to confirm with your print supplier the number of printed canvass communications that you require.
You will need to agree a detailed production schedule with your supplier for your printed canvass communications which should include:
- Timescales for proofing canvass communications
- The volume of printed canvass communications for each route
- Printer deadlines for sending data
- Dates the printer will deliver canvass communications to you (where canvass communications are being delivered back to you ready for onward delivery)
- Scheduling of delivery dates from the printer to Royal Mail, other delivery services or your offices for the purpose of hand-delivery
- Timing of the production and dispatch of any follow-up communications where required
We have designed templates for each of the different printed canvass communications, some of which you are required to use. You can find more information on the template communications and how to use these in our forms and letters guidance.
Your printer will need to produce proofs of the templates for printed canvass communications, and you will need to check these. Once you have approved the template proofs you should send test data to ensure that data fields appear correctly. Our data protection guidance for EROs and ROs highlights the importance of having a robust proof checking process in place when working with a processor in order to detect any errors and avoid data breaches before they occur.
If you are planning to use Royal Mail or other delivery services you should consider the delivery options they offer and any discounts based on the types and volumes of printed communications you expect to send out to determine which option will best meet your needs.
How should I decide which response mechanisms to make available during the canvass?
You will need to decide which response mechanisms you will make available for electors. These may vary for the different canvass routes and the different contact stages within routes, and should be considered alongside the outward contact methods you intend to use.
Potential response channels include:
- Website
- SMS
- Post
- Telephone
- In person
You should ensure that your chosen response mechanisms are designed to meet elector expectations and enable them to respond as easily as possible where needed. For example, if you contact some electors via email, they may well expect to be able to respond online, such as by a return email, rather than a different channel.
You could also consider the demographics of your local area to help inform your decisions. For example, if you know you have a high population of older people, areas with limited access to internet, or areas with high levels of socio-economic deprivation, you will need to consider which response mechanisms would be most appropriate to meet the needs of your electors.
If you decide to use automated response services – which would typically involve using security codes to log onto a website or respond by an automated telephone or SMS response service – you will need to decide whether to manage this internally or to outsource the work to an external supplier.
If you are using an external supplier, you will need ensure that they will be able to meet your requirements before agreeing the process for setting the service up, finalising contracts and reflecting your decisions in your canvass plans. Any person who will be processing personal data for use with response services must comply with the requirements of data protection legislation.
Planning for staffing to deliver the annual canvass
As part of your planning you will need to think about what staff you require to carry out the canvass.
This section contains guidance on how to identify what staff you will need and plan for the delivery of any necessary training.
How do I plan my staffing requirements for the canvass?
The council which has appointed you as ERO is under a legal obligation to provide you with the necessary staff to enable you to fulfil your statutory duties.1
The decisions you have made on your approach to delivering the canvass will impact on the number of staff you may need. You will need to consider how you will resource the following:
Managing the local data matching exercise
If you are carrying out local data matching, the volume and the timing of this may have an impact on the amount of staff time you will need. You will also need to consider any additional work needed to get the data into useable format for data matching purposes.
Analysis of the data match results
If you are carrying out local data matching, you should consider the staff resource required to make decisions where national and local data match results conflict. You will also need to consider the staff-time required for the property allocation stage.
Dealing with questions from the public about the canvass process
Establish the staffing levels required by thinking about the timings for your canvass activity across the different routes and identifying the likely peak response periods. Your decision on whether these queries will be managed by a contact centre or by the electoral services team will also have an impact on the amount of staff required.
Processing responses
You will need to consider the staff required to manage multiple response channels, deal with any conflicting responses and undertake any additional registration activity necessary - for example sending ITRs, undertaking reviews and deletions.
Hand-delivering communications (where undertaken)
If you are hand delivering canvass communications, you will need to consider the geography and size of the canvass areas. Canvass areas can vary in size to help maximise canvass response rates, allowing you to take into account the varying geography and demographics of different parts of your registration area. For example you may want to allocate fewer properties over larger geographical areas, such as rural locations. The size of canvass areas will also be affected by the staff resource available, the more staff you have, the smaller your canvass areas may be.
You may wish to review your canvass areas following the allocation of properties to canvass routes in order to ensure that canvassers have sufficient time to contact all non-responding properties/individuals based on the number of Route 2 properties in that area.
You will also need to consider the likely volumes of canvass communications that you intend to deliver by hand. For example, are you hand delivering some or all of the canvass communications and at what stage for each route?
You will also need to consider the impact on staff resource requirements where you are combining hand delivery with a property visit.
Undertaking personal contact via telephone or property visits
The decisions you have made on how you will carry out the personal contact requirements for Route 2 properties will impact on the size of canvass areas and the staff resource you will need to ensure you maximise the effectiveness of personal canvassing.
For example:
- the stage of the canvass that personal contact will take place will have an impact on the volume of properties requiring contact. The more properties that require personal contact, the smaller the canvass area may need to be
- the size of the canvass area will be impacted by the number of staff undertaking personal contact attempts by either visit or by telephone
- if by telephone whether it will be done by your electoral services team, or a contact centre
- the size of the canvass area may depend on how many personal contact attempts you will make, the more attempts you plan to make, the smaller the canvass area may need to be
- if you are combining any follow up of ITRs for individuals within a property with any personal contact attempts the smaller the canvass area may need to be
You will also need to review your existing canvass staff database. You should review the performance of canvassers who have worked on your canvass before and any whose past performance has been unsatisfactory should not be used again. You should then make contact with those you wish to invite to work on the canvass again bearing in mind that existing or experienced canvassers may not be available and you may need to undertake recruitment to identify and select new canvassers.
Where you need to undertake recruitment of staff to work on any part of delivering the canvass, you will need to take into account the length of time required for recruitment and plan accordingly. You should liaise with your HR contact to ensure they are aware of your requirements and can provide you with the necessary support. You will also need to ensure that your recruitment plans are fully reflected in your canvass plan.
- 1. Section 52(4) RPA 1983 ↩ Back to content at footnote 1
What training do I need to provide for staff working on the canvass?
Your duty to maintain the registers of electors includes the provision of training to all the staff you have appointed to assist with delivery of the canvass.1
You should review the training needs of both permanent and temporary staff, including canvassers. It is important that all staff understand their particular role and any statutory obligations associated with the work they are undertaking. As well as training on the legislative requirements and responsibilities relevant to their role, it is important that staff are trained on ensuring equal access, data handling and good customer care.
To embed data protection principles in your work and demonstrate compliance with the legislation, you will need to ensure that all staff, including canvassers, are trained in handling personal data. You should discuss any data protection training with your Data Protection Officer.
Appropriate training will also need to be provided for all front-line staff to reflect the fact that 14 and 15 year olds can be included on the local government register as attainers. For example, staff will need to be given training and guidance relating to handling and storing the personal data of 14 and 15 year olds.
Your systems should be set up in such a way as to ensure that the data of 14 and 15 year olds is only used for the limited purposes set out in law.2
Where you identify that training is required, you will need to make arrangements for this to be provided and reflect this in your canvass plans.
You may already have existing structures for training sessions and materials for their delivery which you can review and refine to ensure they are relevant and appropriate.
If you have training personnel within your council, they may be able to assist you with this process.
What training is required for staff dealing with enquiries about the canvass?
You will need to identify how you will support staff dealing directly with the public by phone or face-to-face, whether in the office, undertaking personal visits or working at any contact centres or call management centres.
Staff will need to understand the differences between the different canvass communications and be able to:
- offer advice about whether or not a response is required
- encourage a successful response to the canvass communication as required when speaking to someone on the telephone
- give advice on registering to vote, the options available to make an application to register and, where appropriate, assist with the registration process
- apply knowledge to deal with a person’s individual circumstances
- be able to identify non-standard questions and refer these to staff with more detailed knowledge of registration as necessary
To support front-line staff we have produced a frequently-asked questions (FAQs) document covering a range of queries that may arise about electoral registration.
You can adapt this document to reflect your local approach to the canvass.
Planning training for canvassers
You need to ensure that your canvassers are trained to carry out the job they have been appointed to undertake. You may need to deliver different types of training sessions depending on how you intend to deploy them. For example, those making house to house visits may require different training to canvassers who are making telephone contact.
All canvassers must receive appropriate data protection training and be trained as to how to keep any personal information they collect from electors safe.
Further information on the recruitment and training of canvassers can be found in our Canvasser recruitment and training checklist.
Resources to support the management and briefing of canvassers can also be found on our website.
- 1. Section 9A of the RPA 1983 ↩ Back to content at footnote 1
- 2. Section 14 Scottish Elections (Reduction of Voting Age) Act 2015 ↩ Back to content at footnote 2
What do I need to consider when planning the publication of the revised register following the canvass?
When planning your canvass timetable you will need to take into account the requirement to publish your revised register by 1 December, unless there has been an election during the canvass in which case you can delay publication up until 1 February.1
Publication of the register on 1 December maximises the length of time available for applications to register to be received and determined in time to be included on the revised register.
If 1 December falls on a weekend rather than a working day, there may be specific practicalities you will need to address to ensure you’re still able to publish. For example, you would need to factor into your planning the possible resource requirements related to working on a weekend, such as the opening of office buildings, staffing arrangements and the availability of IT support if required.
You should bear in mind that not all of your canvass activity needs to be completed by 1 December, regardless of when you publish your revised register; any outstanding steps can be picked up as part of your year-round electoral registration activity.
If, for whatever reason, you decide to publish on a date in November instead of on 1 December, you will need to consider the impact on your canvass plans of the earlier deadlines for receipt of applications in time for them to be determined and included on the revised register. Publication of the revised register in November means that some individuals who make a successful registration application from late October onwards, would not be added to the register until the January notice of alteration, unless they are added by any election notice of alteration.
- 1. Section 13(1) and (1A) of RPA 1983 ↩ Back to content at footnote 1
Data matching for the annual canvass
This section of the guidance covers what you need to know about the national data match step including what it is, what data you need to include and exclude, how and when to send your data and how to process the results and allocate properties to canvass routes.
What is the national data match step
What is the national data match step?
Each year, before conducting the annual canvass, you must disclose data to the Minister for the Ministry of Housing, Communities and Local Government as part of a national data matching exercise known as the national data match step.1
The national data match step involves the checking of information about existing electors on your register - their name, address including the UPRN where held and, where known, date of birth, against data held by the Department for Work and Pensions (DWP).
The purpose of the exercise is to help you identify properties where residents may have changed. This information should then be used to determine the route you will use to canvass each property.
- 1. Regulation 32ZBB, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What data do I need to send?
What data do I need to send?
The data you send for the national data match step in relation to all persons aged 16 or over who appear on the parliamentary and local government registers must include:1
- the full name, including any middle name(s) or initials you may hold
- the date of birth (where held)
- the full address, including postcode
- Unique Property Reference Number (UPRN) (where held)
- any other information that you hold relating to a person’s entry on the register, if the Ministry of Housing, Communities and Local Government specifies such information in writing (for example, a previous surname). This additional information may improve the likelihood of a data match as the information you hold may show a link exists between the data held nationally and your data.
14 and 15 year olds are excluded from the national data match as their details are not held by DWP.
- 1. Regulation 32ZBB, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Who will be excluded from the national data match step?
Who will be excluded from the national data match step?
Certain types of electors must be excluded from the national data match step.1 These are:
- 14 and 15 year olds
- all special category electors
You should also exclude the following electors and properties from the national data match:
- Determined electors – individuals who have had their application determined and will be added to the register by the next notice of alteration. These electors will have only just been added to the register so will be considered matched by default.
- Determined deletions – individuals who you have determined are no longer entitled to be registered and will be deleted from the register by the next notice of alteration.
- Empty or void properties – as no electors are registered at these properties, there are no individuals to be matched against DWP data as part of the national data match step.
Special category electors
The following special category electors must be excluded from the national data match step, as they are not included within the annual canvass process:2
- overseas electors, i.e. British citizens living outside the UK
- HM Forces service voters (and their spouses or civil partners and those under 18 years old, living with their parent or guardian and their parent or guardian is a member of the armed forces)
- Crown servants and British Council employees (and their spouses or civil partners and those under 18 years old, living with their parent or guardian and their parent or guardian is a Crown servant or British Council employee and they would be living in Scotland if their parent or guardian were not living overseas)
- electors who have made a declaration of local connection, including people living in the UK who have no permanent or fixed address
- anonymously registered electors, i.e. those who have registered anonymously because their safety would be at risk if they appeared on the register using their name
- patients in mental health hospitals whose stay at the hospital is sufficient for them to be regarded as resident there
- remand prisoners whose stay at a penal institution is sufficient for them to be regarded as resident there
- 1. Regulation 32ZBB, The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBB(8), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
Should recent additions be excluded from the national data match step?
Should recent additions be excluded from the national data match step?
You have the discretion to decide whether to exclude some or all of your recent additions from the national data match step.1
Recent additions are electors who have made a successful application to be registered and have been added to the register of electors within the last 90 days.
Deciding what your recent additions threshold should be
Prior to the start of the national data match step, you should decide where to set the cut-off point for recent additions to the register to be included in the national data match.2 This period must be between 0 and 90 days.
When the data is uploaded for the national data match, any recent additions to the register prior to the threshold date you have set will be excluded from the data match and automatically marked as matched within your EMS.
- If you set a threshold of 0 days, all recent additions will be included within the national data match step.
- If you set a threshold of 90 days, recent additions made within the last 90 days will be excluded from the national data step and automatically marked as matched within your EMS.
- If you set a threshold of between 0 and 90 days, recent additions to the register within your chosen time frame will be excluded from the national data match step. For example, if you choose to set the threshold at 45 days, recent additions to the register in the last 45 days will be excluded from the national data step and automatically marked as matched within your EMS.
Your decision to include or exclude recent additions from the national data match step could have an impact on the outcome of the data match results. In turn, this may influence the canvass route you allocate for each property.
The questions below may help to inform your decision about whether to exclude all or some of your recent additions from the national data match step.
Questions | Impact on your decision |
---|---|
How stable is your electorate? Do you have a high level of churn within your electoral area? | If you have a high level of churn in your area, there is a increased risk that someone may successfully register to vote at an address but then move again in a short space of time. Where this is the case you could consider setting a lower threshold which may help to better capture changes in areas where electors move more frequently. |
Have you checked against locally held data sets that the information you hold for properties identified as having recent additions have no other changes? | If you have carried out checks as part of your activity to maintain the register throughout the year, you could consider setting a higher threshold. You may be more likely to have already captured and managed recent changes and so your local data may be more up to date than DWP records. |
Do you have processes in place to regularly identify and subsequently take steps to remove existing registered electors from a property if they have moved out? | In this case, you could consider setting a higher threshold, as you are more likely to have actioned recent changes and so your local data may be more up to date than DWP records. |
Have you had to process a high proportion of changes during previous canvasses? | If this is the case, you could consider setting a lower threshold as your recent experience suggests that you are less likely to have captured all required changes outside of the canvass period. |
The Ministry of Housing, Communities and Local Government help sheet below provides further information and guidance to help you set your threshold.
You should review the impact of the threshold you set after each canvass to determine its effectiveness, and ensure any lessons learnt are fed into your planning for subsequent canvasses.
- 1. Regulation 32ZBB(7)(a), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBB(7)(a), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
When do I need to send my data?
When do I need to send my data?
As part of your planning for the canvass you should already have considered when you want to conduct the national data match step.
The data matching process will be managed in practice by the Ministry of Housing, Communities and Local Government and will be phased due to the volume of records to be processed.
The Ministry of Housing, Communities and Local Government have advised there will be a tool available that you will need to use to schedule the date for your data upload. Please note that there is a limit on the volume of records that can be processed per day and so if a certain date has reached its capacity, it will no longer be available for you to book on the tool.
Once you have booked through the tool, you will receive an email from the Ministry of Housing, Communities and Local Government confirming that you have successfully booked your date.
The Ministry of Housing, Communities and Local Government will provide you with instructions on when to electronically upload your register to DWP via your electoral management software (EMS) system. Your EMS supplier will provide you with instructions on how to upload your data.
Once you have confirmed the date for your data upload, you will be able to confirm the rest of your plans for the delivery of the canvass, including liaising with and updating your print suppliers as needed.
Using the results of national and local data matching
Using the results of national and local data matching
You have the option to use local data matching before the national data match step, after you have received the results from the national data match step, or both.
Planning for data matching includes guidance on how to identify and use local data.
What will be included in the national data match results?
What will be included in the national data match results?
You should receive your results within 5 working days of the data being submitted.
You will receive your results through your EMS. Your EMS supplier will provide you with instructions on how this will work in practice.
Each elector whose data is sent for the national data match will return with either a match or no match result. The results will not include any details of why an elector’s details failed to match. Your EMS will then aggregate these into a result for each property.
What do I do with the results of data matching?
What do I do with the results of data matching?
The data matching results will help you determine whether the property as a whole is matched or unmatched and you must use this information to help you to allocate that property to the appropriate canvass route.1
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Matched properties - A property is determined to be a matched property where there is a match result for every elector within a property, through national and/or local data. A property can also be determined to be a matched property where you have carried out local data matching and have confirmed the status of the property as empty.
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Unmatched properties - A property is determined to be an unmatched property where you are unable to match some or all of the electors within a household through national and/or local data matching.
Both national and local data matching results may be relevant in determining the appropriate canvass route. For example, you may:
- Accept a match from either local or national data matching
- Override a match result from national data matching where you are satisfied that local data matching information is more accurate - this may be because you believe your local data source to contain more up-to-date information
- Override a result from local data matching if you believe the national data match has provided a more accurate result
What action can I take where an individual is unmatched?
You cannot disregard the results where both national and local data shows at least one elector in the property as not matched.
However, you could consider using other local data sources that you trust to be accurate to try to match the unmatched elector before allocating that property.
If you are able to match an unmatched individual using other local data sources, you may then be satisfied that the whole property is a match and could be canvassed via Route 1 - the matched property route.
Where you do not have additional local data to use, or are unsuccessful in matching the unmatched elector using additional local data, canvass the property via Route 2 – the unmatched property route - as you cannot be satisfied that there are no changes to be captured for that property.
- 1. Regulation 32ZBA(2) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What else can I take into account to help me decide how to allocate properties to canvass routes?
What else can I take into account to help me decide how to allocate properties to canvass routes?
You should consider whether there is any other information you hold, either in written or electronic data format,1 that you could check after the data matching results have been received to inform your decision on which route to use for each property.
Potential electors held on your EMS:
What is this information and why is it useful? |
Potential electors are not registered electors but are individuals who are recorded in your EMS, likely as a result of local data mining or a returned canvass form, who may be eligible but have not yet registered to vote at the address. This information is useful because it may indicate that there are changes required to the register for that property, with individuals potentially being resident who have not yet made a successful application to register. |
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What action could I take? | Check local data to try to confirm if these individuals appear to be still resident. |
What impact could this information have on my decision making? |
Where local data matching shows an individual does still potentially reside at the address but has not yet registered, it may be most appropriate to canvass the property via Route 2 – the unmatched property route. Where local data matching confirms an individual no longer resides at an address, their name can be removed as a potential elector from EMS and the property could be canvassed via Route 1 – the matched property route if all other individuals at a property have been matched. |
Information provided from another ERO:
What is this information and why is it useful? | Other EROs may have information about individuals who have moved into or out of your area. |
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What action could I take? |
Check any information sent to you by another ERO for any additional potential changes at a property. If you are notified that an elector is no longer resident at an address, you should initiate the deletions process. |
What impact could this information have on my decision making? | If after checking information sent to you by another ERO, you are now aware that there may be changes at a property, you should consider canvassing the property using Route 2 – the unmatched property route. |
Other sources of council data:
What is this information and why is it useful? | Data from other departments in the authority could help you to identify additional potential electors or other changes at a property. |
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What action could I take? | Check all council data you have access to for information on any additional potential electors or other changes at a property. |
What impact could this information have on my decision making? | If after checking data from other council departments, you are aware of additional potential electors or other changes at a property, you should consider canvassing the property using Route 2 – the unmatched property route. |
You will need to consider how you will evidence and document your decision-making if information from a source other than the results of data matching leads to a decision to change a property from one route to another.
- 1. Regulation 32ZBA(8),The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Processing information in connection with data matching
Processing information in connection with data matching
This section of the guidance covers data protection considerations in regard to data matching.
Information supplied to the Minister for the Ministry of Housing, Communities and Local Government for the purpose of the national data match and the access to the results from the national data match step are subject to certain restrictions.
You must not disclose any information from the national data match step about an individual1 to any person other than where they are responsible for deciding the most appropriate canvass route or for the purposes of any civil or criminal proceedings.
However, data protection legislation allows individuals to make requests about the information you hold about them. For more information on subject access requests (SARs), including how they relate to the national data match, see our guidance - What should I do if I am asked to disclose information from the national data match?
If you, or anyone authorised to act on your behalf, discloses data from the national data match step for any other reason you (and they) could be subject to imprisonment, a fine or both.
- 1. Regulation 32ZBC, Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What should I do if I am asked to disclose information from the national data match?
What should I do if I am asked to disclose information from the national data match?
If you receive a request for the data from the national data match for the purpose of any civil or criminal proceedings, you may be able to supply the data in specific circumstances, but you should take your own legal advice before doing so. As part of your ongoing data protection compliance, you should maintain records of every person and organisation supplied with any data to demonstrate that you are complying with the relevant legislation and the principles of processing personal data, and are ensuring that it is processed lawfully, fairly and in a transparent manner.
Subject access requests
Data protection legislation provides that a person may make a subject access request to see personal information that is held about them and this could include a person asking whether or not they were a match during the annual canvass.
If you receive such a request, you must be satisfied of the requester’s identity before fulfilling the request. Information requested by data subjects must be provided without delay and in any event within one month (although this can be extended to two months in certain conditions).
Further information can be found in our guidance - subject access requests.
Are there any other data protection considerations?
Are there any other data protection considerations?
When processing information in connection with the national data match step you must adhere to any requirements that have been imposed by the Minister for the Ministry of Housing, Communities and Local Government.1 The Ministry of Housing, Communities and Local Government may provide further guidance on any such requirements.2
Additionally, any data used or processed in connection with the national data match step must be stored securely and processed in accordance with data protection legislation. You should also ensure that your privacy notices and data retention schedules reflect the processing of data for the national and local data match step.
Our data protection guidance for EROs and ROs provides guidance in relation to privacy notices, along with advice about your role as data controller and a checklist to help inform the content of data sharing agreements.
- 1. Regulation 32ZBC(3) and (4), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBC(3) and (5), The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
Allocating properties to canvass routes
Allocating properties to canvass routes
Once you have received and analysed the results of both your national and local data matching (if undertaken) and taken into account any other relevant information you have access to, you need to allocate properties to specific canvass routes.
The following resource provides a description of the three canvass routes and the criteria that determines when a route must be used and when an ERO has the discretion to decide whether to use a particular route or not.
Where you decide to allocate a property to a route based on the results provided by one set of data rather than another, you should be able to explain your decision-making process clearly and maintain an audit trail of your decisions.
It is important to note that whilst you will have the option to consider individual property level data match results when allocating properties to routes, you won’t necessarily need to do this in practice. You should be able to apply the allocation criteria more broadly so that properties with the same data match results can be managed in the same way and allocated to the appropriate routes in bulk.
Route 1 – the matched property route
Route 1 – the matched property route
When you have completed your data matching and allocated properties to canvass routes, you can begin to deliver your canvass plan.
This section covers Route 1 and includes guidance on when you can use Route 1, what canvass communications you can use for this route and how to process responses.
What is Route 1 and when can I use it?
What is Route 1 and when can I use it?
Route 1 is the matched property route. It can be used to send canvass communications to properties where you are satisfied that no changes are needed based on the results of national and any local data matching.
A link to a visual overview of Route 1 is below:
Properties can be canvassed using Route 1 where:1
- You are satisfied that there are no changes needed at that property and you have no reason to believe that there are any additional electors to be added.
- You have carried out local data matching to confirm the status of the property as empty or void.
- 1. Regulations 32ZBA(4) and 32ZBE(1) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What communications should be used for Route 1 properties?
What communications should be used for Route 1 properties?
Route 1 communications provide the occupants of each property with an opportunity to inform you of any changes or incorrect information you hold on the electoral register for that address.
You must issue a communication to each Route 1 property. There are two communication options open to you for the initial communication:1
- An e-communication:2
- Can be sent via any electronic channel
- If used, must be sent to every registered elector aged 16 or over that you hold the relevant electronic contact details for in the household3
- Requires a response, even if no changes are required for the property4
- Requires follow up action if no response is received within a reasonable timeframe5 (i.e. if no response is received to the initial e-communication or any reminder from at least one person within the household, Canvass Communication A must then be sent)
- Canvass Communication A (CCA):6
- Is a prescribed paper communication
- Can be hand delivered or sent by post
- Must be sent if you have been unable, or choose not, to use an e-communication
- Must be sent if you do not receive a response to an e-communication from an individual within the property within a reasonable timeframe7
- Does not require a response, unless there are changes for the property
- Does not require any follow up unless you are made aware of or have reason to believe there are changes for that property that require further action
It is an offence for an individual to fail to notify you of a change, or to provide false information in response to a Route 1 communication.8
- 1. Regulations 32ZBA(4) and 32ZBE(1) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBE(3)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
- 3. Regulation 32ZBE(3)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
- 4. Regulation 32ZBE(4) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 4
- 5. Regulation 32ZBE(5)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 5
- 6. Regulation 32ZBE(3)(a) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 6
- 7. Regulation 32ZBE(5)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 7
- 8. Regulations 32ZBG(4) and 32ZBG(4)(e)(i) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 8
What is an e-communication and when can I use it?
What is an e-communication and when can I use it?
An e-communication could be an email, SMS text message or another type of electronic or digital communication, such as a communication through internal accounts used to communicate with electors about other local authority services. A response is required to an e-communication, even if there are no changes to report.
Whilst the e-communication you send must inform the recipient of the requirement to respond, you need only receive a response from one recipient of an e-communication within a household to meet the response requirement for that property.
An e-communication provides you with an opportunity to encourage a response from a property to update the information you hold on the register via an alternative channel than by post. This could potentially lead to resource savings.
To use an e-communication you must have the relevant contact details for at least one of the electors aged 16 or over registered in the household.1
You can still use an e-communication if you only hold contact details for some but not all registered electors at a property, although you must send an e-communication to all electors aged 16 or over whose contact details you do have.2
Using a mixture of e-communication methods
You can, if you wish, use different types of e-communications for different properties: for example, you could choose to send a mixture of emails and text messages or any other type of e-communication to different properties depending on the contact data you hold.
You can also send a mixture of e-communications within a household. However, there is no requirement to use more than one type of e-communication to contact a property so, for example, if you hold email addresses for some individuals and mobile numbers for others, you could decide only to use e-mail contact, in which case you would only need to send the e-communication to those individuals with email addresses.
Choosing which types of e-communication method(s) to use
When deciding which, if any, e-communication method to use, you should consider:
- whether you hold the information necessary to use the contact method you are considering, or if you are able to obtain and use contact information from any other sources in line with data protection considerations
- the number of individuals you hold the necessary information for
- how confident you are that the contact data you hold is accurate and up to date
- the capacity that your local authority has for sending out bulk emails/SMS messages
- whether to send out e-communications in batches in order to help manage the workload created by a high number of responses
- how you will process responses received through different communication channels, including queries from electors
- what steps you will take to be sure that any communication channels you use and any actions taken comply with data protection legislation
- how you will ensure that electors will know that e-communications you send are genuine, so they can be confident in responding accordingly
You cannot use e-communications for any empty and void properties as these properties do not contain any registered electors for you to contact electronically.
- 1. Regulations 32ZBA(4) and 32ZBE(1) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBE(3)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
What information should an e-communication contain?
What information should an e-communication contain?
The design of an e-communication is not prescribed. However, we provide a template e-communication, and other information in our forms and letters guidance.
Any e-communication must require the recipient to:1
- confirm whether the information for all electors is complete and accurate
- provide details for any other eligible electors who are not listed on the communication. These details include their name, nationality and the date of birth of any person aged 14 or 15.2
Your e-communication must inform the recipient that they are required to respond and should also:
- provide the recipient with a deadline for response
- include information on the response channels available to them and instructions on how to use them
- include a link to the UK Government’s registration website (gov.uk/register-to-vote)
- inform the recipient how you obtained their contact details and give them the opportunity to opt-out of further e-communications
- 1. Regulations 32ZBA(4) and 32ZBE(1) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBE (4A)(b)(c) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
What is a successful response to an e-communication?
What is a successful response to an e-communication?
You must receive a response to an e-communication from at least one elector in a household within a reasonable period of time, even where there are no changes to the information for that property.1
A successful response to an e-communication can be defined as one which either:2
- confirms that all of the information is complete and accurate
- provides new information regarding who is resident at the property
- provides new information regarding changes required to an elector’s details
- provides new information indicating an existing elector is no longer resident at the property
or provides any combination of the above.
You only need to have received a successful response from one elector contacted via an e-communication to be satisfied that you have received a response for that property.3
Making additional enquiries
You can make additional enquiries if you receive a response that indicates a change may have occurred at the property but does not include enough information to provide a successful response as above.
If as a result of making additional enquiries you are able to get information needed to provide a successful response, you can close the route and undertake any additional actions required, for example, beginning the ITR process for new residents at the property.
If you are unable to obtain the information that is needed to provide a successful response, you must transfer the property to Route 2 – the unmatched property route, as you can no longer be satisfied that there are no changes to the property. For example, a response may suggest that there are potential new electors at the property but may not give their names. If you are unable to obtain the names of the potential new electors having made additional enquiries, this would require you to move the property to Route 2.
What action to take if no response is received
Where no response is received within a reasonable time period, you must send a CCA to the property.4 However, you may choose to send a reminder e-communication before sending the CCA.
While a reasonable period of time is not defined in legislation, in our view this should be no longer than 28 days and may in some circumstances be shorter (for example, where you are approaching the conclusion of the canvass or where there is an election due to take place).
- 1. Regulation 32ZBE(4) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBE(4) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
- 3. Regulation 32ZBE(5)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
- 4. Regulation 32ZBE(5)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 4
Responses to Route 1 e-communications
Responses to Route 1 e-communications
If you decide to use an e-communication then it is up to you to determine the most suitable response mechanism(s) for your area.
For example, you could decide to signpost within your e-communication to an automated online, SMS or telephone response service which collects the required information. You could also allow responses to be provided in person, by email or by telephone, either to a call centre or directly to your team.
Managing changes to a property
If you receive information in response to a Route 1 e-communication telling you about changes, you should take action to process the information in the response as necessary.
What if more than one response is received?
You will need to ensure that you can identify where more than one individual within a property has responded to an e-communication and are clear on what actions you will take if there is any conflicting information in the responses.
For example, if you receive a response from one elector confirming that all the information is correct and accurate and you receive a response from another indicating that someone needs to be removed from the register at the property, you will need to make further enquiries to confirm the details of the property. If you believe that there may be changes needed to the property but are unable to confirm enough information to enable you to carry out review or ITR processes, then you must transfer that property to Route 2.
What should I do with email bounce backs?
An email bounce back is where an email is undelivered and returns a notification back to the sender. There are two types of bounce backs:
- soft bounce – this is where delivery is delayed while the email server re-attempts delivery a number of times over a period of hours or days and is only considered undeliverable if the retry period expires without success
- hard bounce – this is where the email address is deemed permanently undeliverable
Where a hard bounce occurs you should remove the email address from your database and then send a CCA to the property if you have no other e-communication options for individuals at the property.
In the case of a soft bounce you will usually need to wait to see if a hard bounce occurs as a result of still being unable to deliver the message after further attempts.
You should have a process in place to enable you to identify bounce backs and take appropriate action. We have created the table below which identifies some of the common reasons for bounce backs and action you may wish to take where this occurs.
Reason for bounce back | Action to take |
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Email blocked by the recipient (hard bounce) |
There is nothing you can do as sender to prevent this. You should remove the email address from your database and send a CCA to the property if you have no other e-communication options for any individuals at the property. |
Email address is invalid – for example, wrong address provided or transposed incorrectly (hard bounce) |
Check your email data source for accuracy. If the address has been transposed incorrectly, correct the error and re-send the e– communication. If the address has not been transposed incorrectly – you should remove the email address from your database and send a CCA to the property if you have no other e-communication options for any individuals at the property. |
The email is blocked by the server – for example, the email is in wrong format, too big or recognised as spam (hard bounce) |
In advance of sending, review your ecommunication carefully, including with your IT team, and identify any potential reasons the email may be blocked - such as large graphics, photos or other corporate branding. Corporate branding that needs to be included as a way to signpost that the e-communication is genuine should be of a size that will be accepted by the receiving mailbox/server. |
Receiving server is unavailable (soft bounce) |
There is nothing you can do as sender to prevent this. This will become a hard bounce if no action is taken by the receiving server. |
Receiving mailbox is full (soft bounce) |
There is nothing you can do as sender to prevent this. This will become a hard bounce if no action is taken by the owner of the mailbox. |
Respondent has an autoreply service set up (soft bounce) |
There is nothing you can do as sender to prevent this. The email may still be delivered but you should check the content of the auto reply and make a decision as to whether further action is required. For example, the individual may have left a place of work. In this case, you could treat the auto response in the same way as a hard bounce. |
If you receive bounce backs and have no other electronic method for contacting individuals at a property, you should continue with the Route 1 process by sending a CCA to the property.1 There is no requirement to re-allocate the properties to Route 2 unless you believe that there may be changes required at the property.
You will need to take steps to ensure that any email addresses which resulted in a hard bounce back are removed from your database to ensure the accuracy of the contact information you hold for future canvasses.
- 1. Regulation 32ZBE(5) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What information is included in Canvass Communication A (CCA) and when can I use it?
What information is included in Canvass Communication A (CCA) and when can I use it?
Canvass Communication A is a paper communication used for contacting matched properties as part of the Route 1 canvass. It provides residents with details of the individuals currently registered at the address and encourages a response if there are changes required.
The format of the CCA is prescribed1 and you must also include certain information about each person currently registered at the address.
You must pre-print:2
- full name and nationality for all registered electors, including attainers and those individuals who have had their application recently determined and will be added to the register by the next notice of alteration prior to the CCA being sent
The CCA must also include:
- Any information about how residents can respond if any of the information is inaccurate or incomplete3
- A statement setting out that, where a response is provided because any of the information is incomplete or inaccurate, the responder will be required to declare that the information they provide is true4
- A statement on how the data will be used and processed5
The CCA must not include:6
- the details of any Special Category electors
- details of any individual you are aware of but who has not yet successfully registered to vote, even if you think they may be resident and eligible to register
We provide more guidance to help you with the production of the CCA in our forms and letters guidance.
A CCA must be sent where:7
- you have previously sent an e-communication for a Route 1 property and have not received a successful response from at least one person at the property to whom a e-communication was sent within a reasonable timeframe
- you have been unable to send an e-communication to at least one individual at a property
- you have decided not to use e-communications for a Route 1 property
There is no requirement to receive a response to a CCA.
- 1. Regulation 32ZBE(5) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBE(6) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
- 3. Regulation 32ZBG(3)(e) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
- 4. Regulation 32ZBG (3)(e)(i) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 4
- 5. Regulation 32ZBG(3)(c) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 5
- 6. Regulations 32ZBE(6)(a) and (b) The Representation of the People (Scotland).Regulations 2001 ↩ Back to content at footnote 6
- 7. Regulation 32ZBE(5) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 7
Responses to Canvass Communication A (CCA)
Responses to Canvass Communication A (CCA)
While households are obliged by law to let you know if any of the information contained on the CCA is inaccurate or incomplete,1 there is no requirement for you to follow up non-responses to a CCA. You should, however, follow up on any CCAs that are returned by Royal Mail as undeliverable or return to sender.
What response mechanisms are available for a CCA?
It is up to you to determine which response mechanisms you will make available for individuals to use where they need to notify you of changes in a property after receiving a CCA.
You must pre-print details of your chosen response mechanisms on the CCA.2 The types of response mechanisms you may wish to provide are:
- Telephone, either to a call centre or directly to your team
- Web
- Text
- In person
- Post (note - there is no legal requirement to include a pre-paid reply envelope with a CCA, reflecting that the form itself is not intended to be returned)
When making a decision as to what response mechanisms to offer you will need to consider:
- If a response is returned by post that indicates changes to a property, how will you ensure that you are satisfied that the information provided is accurate to enable you to process the changes?
- The demographics of your canvass area – for example if you know you have a high population of older people, areas with limited access to internet, or high levels of socio-economic deprivation, you will need to consider which response mechanisms would be most appropriate to meet the needs of your electors.
- Whether the response mechanisms you offer ensure that there is an accessible way for individuals to provide details of any changes to you.
- Whether the response mechanisms you offer will also signpost to potential new electors to register via the register to vote website
- How you will manage the processing of responses through different channels – for example, if you are considering using a channel you have not used previously, you will need to ensure you have the right processes in place to manage responses through this channel, including considering how it will interact with your EMS system. You should also consider any additional resource implications from utilising different response mechanisms.
How should I process a response to a CCA?
Where someone responds to a CCA, whether to correct inaccurate information or to add missing information, you will need to check that their response includes all the information you require to fully process the response. For example, has the response provided enough information to start the ITR or review process? You can make additional enquiries if the response does not include enough information to close Route 1.
If as a result of making additional enquiries you are able to get the information needed to provide a successful response, you can close Route 1 and continue with the ITR or review process as appropriate for the property.
If you are unable to obtain the information that is needed to provide a successful response, you must transfer the property to Route 2 – the unmatched property route, as you can no longer be satisfied that there are no changes to the property. For example, a response may suggest that there are potential new electors at the property but may not give their names. If you are unable to obtain the names of the potential new electors having made additional enquiries, this would require you to move the property to Route 2.
Further information about Route 2 can be found in our guidance for Route 2 - the unmatched property route.
- 1. Regulation 32ZBE(3) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBG(4)(e) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
Route 2 – the unmatched property route
Route 2 – the unmatched property route
When you have completed your data matching and allocated properties to canvass routes, you can begin to deliver your canvass plan.
This section covers Route 2 and includes guidance on when you can use Route 2, the contact rules for Route 2, what canvass communications you can use and how to process responses.
What is Route 2 and when can I use it?
What is Route 2 and when can I use it?
Route 2 is the unmatched property route. All properties by default start by being allocated to Route 2, and you can use Route 2 for any property at any time.
To be able to canvass a property using Route 1 or Route 3 instead, specific criteria need to be met.
What are the definitions of the different contact types for Route 2?
The different contact types for Route 2 are defined as follows:
- Property contact – this is where either the prescribed Canvass Form or Canvass Communication B (CCB) is sent to the property, or a visit to the address is carried out. Your first contact attempt must be a property contact.
- Individual contact – this is where contact is made using contact details you hold for an individual who has been returned as a match1 through national and/or any local data matching. You could use telephone, email, SMS or another electronic communication method (such as through internal customer accounts).
- Personal contact – this is where an attempt is made to make contact with either the household or individuals registered at the address who have been returned as a match, either by a visit to the property or a telephone call.
What are the contact rules for Route 2?
To meet the requirements of a Route 2 canvass there are a number of contact rules that you will need to follow:
- You must make a minimum of three contact attempts with the property and/or individuals at that property unless a response has been received2
- At least two contact attempts must be with the property, not with an individual
- One of the contact attempts must be via the use of the prescribed Canvass Form
- The first of the contact attempts must be a communication with the property (i.e. a Canvass Form, Canvass Communication B (CCB) or visit to the property), rather than with an individual
- At least one of the contact attempts must be a type of personal contact (i.e. a visit or a phone call)
If any of the criteria above are not met in your first three contact attempts, you must make a further contact attempt to meet any outstanding requirements from the rules and complete the Route 2 process.
Using your local knowledge and experience, you may decide to use different communication methods with different properties at the different contact stages of Route 2. You should speak to your EMS provider to confirm how this could be managed in practice.
You may also decide to send specific communications at different times, depending on how you wish to manage your resources.
The Ministry of Housing, Communities and Local Government has produced a table which sets out the possible options for how different contact types could be used to ensure the Route 2 requirements are met.
- 1. Regulations 32ZBD (4)(b) and (c) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulations 32ZBD (1), (2) and (3) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
What are the communications options for the first contact attempt?
What are the communications options for the first contact attempt?
The first contact attempt must be to a property, not an individual.1
The communication options open to you for a property contact are:2
- Canvass Communication B (CCB)
- Canvass Form
- Visit to the property (i.e. a door knock)
What is Canvass Communication B?
While legislation does not provide detail about what the CCB3 must include in the way that it does for the prescribed CCA (used for Route 1 properties) and Canvass Form, it does require you to use the version designed by the Electoral Commission.
Canvass Communication B:
- Is a paper form
- Can be used as an alternative to the Canvass Form (notwithstanding that one of the three contact attempts required to complete Route 2 where no response is received must be by way of a Canvass Form)
- Does not require a pre-paid return envelope to be included
- Encourages a response to be made via alternative response channels to post – either online or through a telephone response service
- Requires a response even if no changes are required at the property
- Requires follow up action if no response is received within a reasonable timeframe
What is a Canvass Form?
The legislation requires you to use the Canvass Form designed by the Electoral Commission.4
The Canvass Form:
- Is a paper form
- Must be accompanied by a pre-paid return envelope5
- Must be delivered to a property at some point in the Route 2 contact process, unless a response has already been received from the property
- Encourages electors to respond with updated details of the residents at the property
- Requires a response even if no changes are required at the property
- Requires follow up action if no response is received within a reasonable timeframe
We provide more guidance to help you with production of the CCB and Canvass Form in our forms and letters guidance.
- 1. Regulation 32ZBD(1) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBE(3) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
- 3. Regulations 32ZBD(1)(a) and (10) and 32ZBG(1)(a)(iii) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 3
- 4. Regulation 32ZBG(1) The Representation of the People (Scotland) 2001 ↩ Back to content at footnote 4
- 5. Regulation 32ZBD(9)(b) The Representation of the People (Scotland) 2001 ↩ Back to content at footnote 5
What constitutes a visit to a property?
What constitutes a visit to a property?
A visit to a property:
- Involves a canvasser attempting to gather the information required by the Canvass Form or CCB in person from a resident of the property
- Does not require a response to be received on the doorstep, or the door to be answered
- Can involve hand delivering either a CCB or Canvass Form when no response is received on the doorstep, which would meet both the personal contact and the property contact requirements of a Route 2 canvass at the same time
How should I carry out the first contact attempt?
How should I carry out the first contact attempt?
You will need to make a decision about how you will carry out the first contact attempt. Some questions for you to consider include:
- Will you send a paper communication and, if so, which one?
- A CCB may encourage individuals to use the alternative response channels you have in place. An increase in the use of these channels may result in cost savings and reduce the resources you need to provide for processing responses. The demographic of your electors and how likely they are to have access to the different response channels should also be taken into account.
- A prescribed Canvass Form may be familiar to electors, which may encourage individuals to respond at the first contact stage. Remember that even if you do not receive a response at the first contact stage, if a Canvass Form has been sent as part of the first contact attempt, you are not required to send a further Canvass Form at any subsequent contact attempt.
- How will you deliver the paper communication – by hand or by post?
- You will need to consider the costs and resource requirements associated with production and delivery for each option.
- If delivering by hand, will you combine it with a personal visit?
- Where you are delivering canvass communications by hand, you could attempt a personal visit to the property (door knock) first. This attempt to make personal contact with an individual at the property will meet the Route 2 requirement of making at least one personal contact. If there is no answer at the property, you could then deliver the canvass communication.
- You will need to ensure you identify, recruit and train sufficient canvassers for the geographical spread and number of properties requiring Route 2 canvass communications.
Which response channels can be used for Route 2?
Which response channels can be used for Route 2?
Beyond the requirement to include a pre-paid reply envelope with a Canvass Form, it is up to you to determine which response channels you will make available for responding to canvass communications, whether a Canvass Form or CCB. You will need to reflect the available response options in your canvass communications at each stage of the Route 2 process.
The type of response mechanisms you may wish to provide include:
- Telephone (either to a call centre or directly to your team)
- Online via an automated online response management system
- SMS Text message
- Email (either to a managed response service or directly to your team)
- In person
- Post (note - there is no legal requirement to include a pre-paid reply envelope with a CCB, reflecting that the letter itself is not intended to be returned by post)
When making a decision as to what response channels to offer you will need to consider:
- If a response is returned by post that indicates changes to a property, how will you ensure that you are satisfied that the information provided is accurate to enable you to process the changes?
- The demographics of your canvass area – for example if you know you have a high population of older people, areas with limited access to internet, or high levels of socio-economic deprivation, you will need to consider which response mechanisms would be most appropriate to meet these needs.
- Whether the response mechanisms you offer ensure that there is an accessible way for individuals to provide details of any changes to you
- Whether the response mechanisms you offer will also signpost potential new electors to register via the register to vote website
- How you will manage the processing of responses through different channels – for example, if you are considering using a channel you have not used previously, you will need to ensure you have the right processes in place to manage responses through this channel, including considering how each channel will interact with your EMS. You should also consider any additional resource implications from utilising different response mechanisms.
If you do not receive a response to a Route 2 communication, even where no there are no changes to report, you must make further contact attempts until the minimum contact criteria has been met.1
- 1. Regulation 32ZBD(2)The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What are the communication options for the second contact attempt?
What are the communication options for the second contact attempt?
If you do not get a successful response within a reasonable period of time following the first contact, a second contact attempt must be made.1
While a reasonable period of time is not defined in legislation, in our view this should be no longer than 28 days and may, in some circumstances, be shorter (for example, where you are approaching the conclusion of the canvass or where there is an election due to take place).
You can choose to make either:
- a property contact (i.e. Canvass Form, CCB, visit to the property), or
- an individual contact (i.e. email, SMS, telephone or any other electronic communication method), if you hold contact details for any matched individual(s) (aged 16 or over) at the property
Electronic communications (e-communications) are designed to encourage a response to be made by channels other than by post.
Your e-communication must inform the recipient that they are required to respond and should also:
- Provide the recipient with a deadline for response
- Include information on the response channels available to them and instructions on how to use them
- Include a link to the UK Government’s registration website (gov.uk/register-to-vote)
- Inform the recipient how you obtained their contact details and give them the opportunity to opt-out of further e-communications
Whilst the e-communication you send must inform the recipient of the requirement to respond, you need only receive a response from one recipient of an e-communication within a household to meet the response requirement for that property and prevent the need for follow up. You can find out more information on e-communications in the forms and letters guidance.
- 1. Regulation 32ZBD(2)The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
How should I carry out the second contact attempt?
How should I carry out the second contact attempt?
You will need to make a decision about how to carry out the second contact attempt for all properties that have not supplied the information needed to provide a successful response to the first contact attempt.
Some questions for you to consider include:
- Will you try another property contact with a paper canvass communication? If so, which one?
- If you used a CCB for the first contact attempt, you could decide to use a Canvass Form for the second attempt in order to meet the requirement for the Route 2 process that a Canvass Form be sent as one of the three minimum contact attempts where no response is received. You could also consider combining the delivery of a paper communication with a personal contact to the property.
- Will you use individual contact methods?
- How you will process responses received from different communication methods, including queries from electors?
You will need to take steps to ensure that any communication channels you use are secure and that any actions taken comply with data protection legislation so that electors will know that individual canvass communications you send are genuine, and can be confident in responding accordingly.
When using an individual contact method as part of Route 2, you must attempt to make contact with each matched individual at the property that you hold contact information for.1
Using a mixture of e-communications
You can choose to send a mixture of e-communications within a household. However, there is no requirement to use more than one type of e-communication to contact a property so, for example, if you hold email addresses for some individuals and mobile numbers for others, you could decide only to use e-mail contact, in which case you would only need to send the e-communication to those individuals with email addresses.
However, if the contact information for one matched elector is the same as that for another individual in the same property and you have already tried to make contact using that information, for example, if more than one occupier has provided the same telephone number or email address, you do not need to make multiple contact attempts using the same details.
If you decide to attempt to contact individuals by telephone it is important to ensure that a clear audit trail is kept to record that contact attempt - for example, the date and time the call was made, details of who was spoken to, and what (if any) details they confirm or provide.
The response can be provided by anyone at the property: any individual, including those who were unmatched, may answer the call and provide a response.
- 1. Regulations 32ZBD(4)(b) and (c) and 32ZBD(8)(b) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
How should I carry out the third contact attempt?
How should I carry out the third contact attempt?
You must make a minimum of three contact attempts where you have not obtained a response.1 In order to be able to close the Route 2 process in three contacts, you will need to ensure that the contact method you select for this stage will enable you to comply with the contact rules for Route 2.
In determining your contact options for the third contact attempt, you should therefore ask the following two questions:
- Have you already made an attempt to carry out the personal contact requirement of Route 2 – either by telephone call or household visit?
- Have you already sent the prescribed Canvass Form as part of a previous contact stage? It is important to remember that the sending of a CCB does not meet this requirement.
If the answer to both the questions is yes, you can choose from any of the property or individual contact methods available to you (and outlined as part of the first and second contact stages).
If the answer to either of these questions is no, and you wish to complete the Route 2 cycle with the minimum required contacts, you should undertake whichever of the outstanding requirements remain as part of this contact attempt.
If you choose to use a contact method for your third attempt that would not enable you to meet the minimum contact requirements, you will need to make further attempts until the minimum contact requirements have been met or you have obtained a response.
- 1. Regulation 32ZBD (3) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Route 2 responses
Route 2 responses
If you do not receive a response to a Route 2 communication, even where no there are no changes to report, you must make further contact attempts until the minimum contact criteria has been met.1
You will need to check that any response you receive includes all the information you require to fully process the response. For example, do you have enough information to start the ITR or review process?
You only need to have received a response from one individual to be satisfied that you have received a response for that property.
Where you receive a response which confirms that all the information you hold for a property is complete and accurate, once you have processed the response, you can close Route 2 for that property.
Managing incomplete or conflicting responses
Where you receive a response that indicates that a change may have occurred at the property, you will need to check that the response includes all the information you require to fully process it. You can make additional enquiries if the response does not include enough information to close Route 2. For example, if you have been provided with the full name of a potential new elector, but not their nationality, you could make additional enquiries before sending them an ITR.
If as a result of making additional enquiries you are able to get the information needed to provide a successful response, you can close Route 2 and continue with the ITR or review process as appropriate for the property.
If you receive conflicting information from a property you will need to decide what action to take. For example, if you receive a response from one elector confirming that all the information is correct and accurate and you receive a response from another indicating that someone needs to be removed from the register at the property, you will need to make further enquiries to confirm the details of the property.
However, if you have received information to suggest a change may have occurred at a property, but are unable to obtain the information that is needed to provide a successful response through the minimum Route 2 contact attempts, you should continue to make further contact attempts to obtain the missing information required to provide a successful response.
Managing changes to a property
Where you receive a response to a Route 2 communication that indicates that a change may have occurred at the property, you will need to check that the response includes all the information you require to fully process it and you should then then take action to process the information in the response as necessary.
- 1. Regulation 32ZBD(2) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Route 3 - the defined property route
Route 3 - the defined property route
As part of your planning for the canvass you should already have undertaken an exercise to identify Route 3 properties for your area and made initial contact with the responsible person for those properties.
This section provides guidance on what communications you can use for this route and how to process responses for those properties you have allocated to Route 3.
What is Route 3 and when can I use it?
What is Route 3 and when can I use it?
Route 3, the defined property route, allows you to obtain the information required by the canvass for certain types of properties from a responsible person, where one can be identified.
Route 3 properties must meet certain criteria set out in law. More information on the types of properties that can be considered for canvassing via Route 3, along with an explanation of who can be considered to be a responsible person, can be found in what are Route 3 properties and how can I identify them?
You may decide to use Route 3 for certain property types where you believe you are more likely to get a response via a responsible person1 than an individual resident within the property.
However, if in advance of starting the Route 3 process, the data match result for any property shows all individuals resident at that property as matched and you are satisfied that there are no changes at that property to capture, you could decide that it is more appropriate to canvass the property via Route 1 – the matched property route.
Route 3 cannot be used where data match results or other information you hold shows that only individuals under the age of 18 are registered at the property.2
- 1. Regulations 32ZBA(3) and (5) The Representation of the People (Scotland) Regulations 2001 and Regulation 32ZBF(2) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulations 32ZBA(6) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
Developing positive relationships with responsible persons
Developing positive relationships with responsible persons
It is important that you develop and maintain positive relationships with responsible persons to ensure that your Route 3 canvass activity is successful.
You should consider how best to contact responsible persons in your area to ensure that the information is received, understood and acted upon in a timely way. For example, you may wish to make an informal phone call to your contact at the beginning of your Route 3 canvass to highlight that a formal request for information is forthcoming.
You should be prepared to offer personal visits to Route 3 properties early in the canvass process if you consider that face to face communication is most appropriate for dealing with concerns or questions. In some instances, this may be the best way of engaging with responsible persons and gathering the information required.
Setting timescales
You should ask for the information to be provided within a reasonable period of time.1
When setting deadlines for the provision of the required information, you should ensure that they are realistic and achievable, and you should understand the different conditions in which your responsible persons are operating. For example, universities may not be able to provide information about students until the beginning of term.
Once you have agreed your deadline for responses, you should communicate how you will issue reminders or follow up with visits as necessary, to help manage expectations.
Issues with the supply of information
Some responsible persons, for example care home staff, may have concerns about supplying information about residents who may not have the mental capacity to vote. Ensuring that your communications with them are clear and comprehensive will help provide them with the confidence they need to work with you effectively.
You should point out that the purpose of the annual canvass is simply to capture information on who lives at the property to establish who should be invited to register, and identifying people who are no longer resident.
Occasionally, responsible persons may have concerns about supplying the required information because they have doubts about sharing personal data. In these cases you should remind them of your right to request information and reassure them that providing the required information does not breach data protection legislation.
- 1. Regulations 32ZBA(3) and (5) The Representation of the People (Scotland) Regulations 2001 and Regulation 32ZBF(2) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Right to request information
Right to request information
As Electoral Registration Officer, you have a duty to maintain an accurate and complete register. UK law enables you to require anyone to provide information required for the purposes of your registration duties.
In particular, Regulation 23 of the Representation of the People Regulations 20011
states that: A registration officer may require any person to give information required for the purposes of that officer's duties in maintaining registers of electors.
The required information for the Route 3 canvass is set out in what should a Route 3 communication include.
Under data protection principles the ERO is entitled to collect the required information as there is a lawful basis for its processing; the performance of a public task in the public interest, as provided for in electoral law.
If any additional optional information, for example email addresses and phone numbers, is requested, this may be shared if a data sharing agreement is in place between you and the responsible person or organisation, and they have informed individuals about the potential sharing of such information through their privacy notice.
Our data protection guidance for EROs and ROs provides further guidance on complying with data protection legislation.
There is a criminal penalty of a fine up to a maximum £1,000 for failing to provide the information required.2
- 1. Regulation 23 (1) Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 23 (3) Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
What communications should be used for Route 3 properties?
What communications should be used for Route 3 properties?
Communication with any properties being canvassed via Route 3 must be with the responsible person that you have identified as part of your planning.
There is no single prescribed communication method for Route 3 so you have the flexibility to decide how best to communicate with the responsible person for each of the Route 3 properties in your area.
You can contact the responsible person for a Route 3 property by any method you think is appropriate including, but not limited to, the following:1
- Sending a paper communication - there is no prescribed form to be used for Route 3, but the prescribed canvass communications could be useful as templates for the information you need to collect
- Electronic communications – this could be by sending an email where you hold a contact email address for the responsible person
- Visiting the Route 3 property or the office of the responsible person
- By phone – you could decide to contact the responsible person by phone where you hold a contact number for them
Whichever method you choose for communicating with the responsible person at each Route 3 property, you should ensure that you maintain a clear audit trail of contacts you have made.
As a minimum you should record the steps that you have taken to gather the information required by the canvass from the responsible person, for example, by recording the date, time and name of person contacted and the details of any response obtained from the responsible person.
- 1. Regulation 32ZBF(6) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
What should a Route 3 communication include?
What should a Route 3 communication include?
As part of your planning for canvassing Route 3 properties you should have already considered when and how to make initial contact with a responsible person for Route 3 properties.
After this initial contact, you will need to contact them again when you are requesting the information required by the canvass and potentially to follow up with reminder requests. You should ensure that any follow up activity allows time to switch properties to a Route 2 canvass if necessary.
As a minimum, any communication must ask the responsible person to provide the following for each person who is aged 14 or over, eligible to register to vote and resident at the property:1
- Full name
- Nationality
- Date of birth
You should also request the contact details (telephone number and/or email address) for each eligible resident for future contact purposes, but you should make it clear in any communication that the provision of these is optional.
You should also consider how to communicate any relevant data protection information, such as a privacy statement setting out how you will process the information and what it will be used for. You can find more information on this in our guidance on Planning for canvass communications.
What else should I consider when making contact with a responsible person?
Whether you contact the responsible person by email, phone, letter or personal visit, you should ensure that your communications are clear and complete.
There is no prescribed form to be used for Route 3, but the prescribed Canvass Form could be useful as a template for the information you need to collect. Information received this way could be scanned and input into your EMS in a similar way to processing other forms.
We have produced a resource to support you with key messaging for Route 3 communications.
You could also consider whether collecting the information in another format, for example a spreadsheet, would allow for the data to be imported directly into your EMS system. This could be particularly useful when asking for information from universities, for example, where there is a high volume of information to collect.
As with your initial contact, you should ensure that you record the steps you have taken to make contact and request the information. Further guidance on how to communicate with Route 3 properties is given in what communications should be used for Route 3 properties.
- 1. Regulation 32ZBF(6) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
Route 3 responses
Route 3 responses
You will need to check that any response you receive provides the required information for each person aged 16 or over who is residing at the property and is eligible to register.1
If you are satisfied that a response has been received from the responsible person for a property providing the information you need, the Route 3 process should be closed.
Where you receive a response that indicates that a change may have occurred at the property, you will need to check that the response includes all the information you require to fully process it and then you should take action to process the information in the response as necessary.
Should I issue reminders for Route 3 properties?
Where you have requested the required information from a responsible person for a Route 3 property and have not received a response you can, if you wish, remind them to respond.
The reminder could be via a different communication method, or you could use the same communication method as your initial contact. Whatever action you take, you should record the steps that you have taken to remind the responsible person to respond, for example, by recording the date, time and communication method used.
You will need to decide on the timing of any reminders. If you choose not to use a reminder or if a reminder has not led to the provision of the information from the responsible person within a reasonable time period, the property must be transferred to Route 2 and a full Route 2 canvass of that property must be conducted.2
- 1. Regulation 32ZBF(5) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 32ZBF(7) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
Maintaining regular contact with responsible persons
Maintaining regular contact with responsible persons
You should make regular contact with responsible persons both during and outside of the canvass as part of your work to maintain the register.
Monitoring the progress of the Route 3 canvass
You should remain in regular contact with responsible persons during the canvass to check their progress in providing the required information, assist with any queries they may have, and to avoid delaying you from taking the necessary subsequent actions. You should consider how you will monitor the progress of the Route 3 process as part of your planning for the annual canvass.
When making contact with responsible persons, you should set timescales for receiving the required information. You should put a process in place to check that the information has been provided by your deadline. Your EMS system should be able to assist with this, and diaries, electronic calendars or project planning tools may also be useful.
You should monitor responses from Route 3 properties during the canvass to identify which properties you:
- have received the required information from, so the Route 3 process can be closed
- have received some of the required information from, and need to ask for further information
- have received no information from within a reasonable period of time, and need to follow up with a reminder or personal visit
- may need to transfer to a Route 2 canvass
Further guidance on dealing with canvass returns is found in Route 3 responses.
Maintaining contact with responsible persons outside the canvass
It is important to maintain contact with responsible persons throughout the year as part of your activity to maintain the register outside of the canvass period.
As well as ensuring that your contact details for the responsible person at each Route 3 property remain correct in advance of the next canvass you should also ask them to provide updates on residents who have moved in or out during the year. This could be requested on a monthly basis, for example, or in the run up to an electoral event. This would be particularly useful for properties where there are likely to have been a number of changes outside of the canvass period due to the nature of the property, such as care homes or student accommodation. Keeping in touch will also help to build a long-term relationship with responsible persons, and help ensure that the provision of the information you need as part of the canvass takes place as smoothly as possible.
Our guidance on public engagement and registration planning includes further advice on planning for registration outside the canvass, including what records you can inspect throughout the year to identify potential new electors.
The section on maintaining the register throughout the year contains additional guidance on registration activity outside the canvass, for example through sending registration enquiry forms or discretionary communications.
Processing canvass responses
This section of the guidance covers how to process canvass responses. Your registration plans should address how you will deal with each type of canvass response and any follow-up activity that you will need to take.
Responses to canvass communications will fall into the following broad categories:
- all of the information is complete and accurate
- provides new information regarding who is resident at the property
- provides new information regarding changes required to an elector’s details
- provides new information indicating an existing elector is no longer resident at the property
- a combination of the above
- information that the property has no residents who are eligible to be registered
What action should you take when you receive a successful canvass response?
What action should you take when you receive a successful canvass response?
Canvass response indicates all of the information is complete and accurate | You should record that a response has been received to stop reminders from being sent and close the canvass route for the property. |
---|---|
Canvass response indicates an existing elector is no longer resident at the property | You must not automatically delete the elector from the register. You must instead either obtain a second source of evidence or conduct a registration review before you can remove the elector. You can find more information on both in our guidance - deleting an elector from the register |
Canvass response indicates an existing elector is now deceased | You may automatically delete the elector from the register if a response indicates that an elector is deceased, and you are satisfied that the information is correct. |
Canvass response indicates there are new resident(s) at the property |
You must invite potential eligible electors to register within 28 calendar days of receipt unless, in the meantime, they have made an application to register. You do not need to know the full or exact name of a potential elector in order to give them an invitation to register. You do, however, need to have enough information about their name to be able to identify them as an individual. You can find more information in our guidance - inviting individuals to register to vote |
Canvass response indicates an elector's name has changed | You should send a change of name form to the elector. If an elector has changed their name they must complete a change of name form and provide supporting evidence of the change for the electoral register to be updated. You can find more information in our guidance - processing a change to an elector's name |
Canvass response indicates an elector's nationality has changed |
You should send an invitation to register to an elector whose nationality has changed. An elector who was previously registered only in the register of local government electors must make a new application if they become a British citizen, a citizen of the Republic of Ireland or a citizen of another Commonwealth country, so that they can be added to the register of UK Parliamentary electors. The new application will need to go through the application, verification and determination process again. You can find more information in our guidance - processing a change to an elector's nationality |
Canvass response indicates a change to an elector’s open (edited) register preference | Where the canvass response clearly indicates that a person wishes to opt out of the open register (for example, if only one elector resides at the address and they have indicated they wish to be removed from the open register), you should treat the canvass response as a notice under Article 21 of the GDPR and amend their open register preference in line with their request. If you are in any doubt as to whether the request comes from an individual elector (for example, if there are multiple electors at the address) or as to their intentions, you should contact the elector(s) to explain what the process is for changing their open register preference, and ask for confirmation before processing the request. This includes if you receive a response from one person that seems to make a request on behalf of everyone listed on the form. You can find more information in our guidance – processing a change to an elector’s open register preference |
What are the penalties for failing to respond to a canvass communication or providing false information?
What are the penalties for failing to respond to a canvass communication or providing false information?
With the exception of a Canvass Communication A, a person who has received a canvass communication must provide the information that it requires to the ERO, but there is no requirement for the form itself to be returned.1
There is a criminal penalty of a fine up to a maximum of £1,000 for failing to provide the information required to the ERO.2
The penalty for providing false information to an ERO is up to six months imprisonment or a fine of up to £5,000.3
- 1. Regulation 23(1) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 1
- 2. Regulation 23(3) The Representation of the People (Scotland) Regulations 2001 ↩ Back to content at footnote 2
- 3. Sections 13D(6) The Representation of the people act 1983 ↩ Back to content at footnote 3
Elections during the annual canvass
Elections during the annual canvass
This section of the guidance covers the areas you will need to consider and decisions you will need to take in relation to both the delivery of the canvass and the management of electoral registration for the poll, if an election is held during the canvass period.
What do I need to consider if an election is held during the annual canvass?
What do I need to consider if an election is held during the annual canvass?
An election during the canvass period may reduce the amount of time you have for follow-up activities for both canvass communications and ITRs.
Your canvass plan and risk register should include details of how you will redeploy resources to target registration in any areas in which an election takes place.
If any of the elections listed below, including general or by elections, are held between 1 July and 1 December, you will need to make a decision whether to delay publication of the revised register and, if so, by how much.
In these circumstances publication of the revised register can be postponed up to 1 February the following year.
- UK Parliamentary elections
- Scottish Parliamentary elections
- Local government elections
The impact of any election may depend on which stage of the canvass you are at and how many polling districts are affected by the election.
You will need to be satisfied that you will have sufficient time to take all necessary steps to ensure your registers are as accurate and complete as possible by the time of publication.
In reaching your decision you should consider the impact that postponing the publication of the revised register may have on canvass processes.
For example, where publication of the revised register is postponed, personal canvassing may take place later in the year where reduced daylight hours may impact on the willingness of canvassers to knock on, and non-responders to open, their doors. Inclement weather may also impact a later canvass, and response rates may reduce over the festive period.
Where you decide to postpone publication due to an election, you should take steps to make local political parties and elected representatives aware of the changed register publication date at an early stage.
As detailed in the guidance for monthly notices of alteration during the canvass period, there is no requirement to publish a monthly notice of alteration in the month you are publishing the revised register or in the two months before that day, but you may do so if you wish.
Therefore if publication of the revised register has been postponed to, for example, 1 February, you will publish a monthly notice of alteration in October and November; you are not required to publish one in December or January, but you may do so if you wish.
How can I target new electors if an election is held during the canvass?
How can I target new electors if an election is held during the canvass?
If an election is to be held during the canvass, your focus will need to be on any new potential electors identified who have not yet registered.
You should consider how best to use your resources to target these individuals and to chase up responses to any Route 2 or 3 canvass communications, so that as many eligible electors as possible are registered in time for the election.
Your plan should address such things as:
- what canvassers will have to do differently
- how canvass staff will be informed of an election and given their revised instructions
- what you will do to maximise returns in the affected area(s) to reduce potential disenfranchisement
- how you will identify and prioritise the processing of canvass communications and ITRs for the affected area(s)
- how the canvass will resume after the election
- when you will publish the revised register and what factors will be considered in making the decision
- how you will communicate decisions to local political parties, elected representatives and other interested individuals and groups
Printing polling districts on canvass communications and ITRs will enable you to quickly identify and prioritise these forms where an election is in only part of the registration area.
You can include other registration-related information in the same envelope as an ITR, such as information about the registration deadline for a forthcoming poll.
If the election affects the whole of the registration area, it will be particularly important that your resources are targeted to maximise the number of eligible electors registered in time to participate in the election.
Every effort should be made to conclude all visits well in advance of the registration deadline, but, given the time constraints and depending on the timing of the election, this might not always be feasible.
You should use local data records and your knowledge about your local area to identify any new electors, and any properties where there are likely to have been changes. These could then be prioritised for personal visits.
You could also consider amending your approach to follow up activities for any non-responding Route 2 or Route 3 properties in the area affected by the election. For example, you might choose to send additional e-comms reminders or make personal contact by phone instead of face to face visit where possible.
The local authority that appointed you as ERO must, by law, provide you with the resources you need to discharge your statutory functions.
Use local media and public awareness exercises to set out to residents how they can register to vote in time to be included on the register for use at the election.
In the event of any UK-wide poll during the canvass, it will be important to link your local messaging with any communication activity by the Commission in order to maximise its impact.
Where the election crosses local council boundaries, you should liaise with the ERO in the other local council(s) to ensure a consistent approach and messaging across the electoral area.
How can I use my canvassers to target new electors if an election is held during the canvass?
Your plans should be flexible enough to allow you to re-allocate staff resources to ensure as many responses as possible are collected and returned to the electoral registration office from the relevant the area(s) in time to be processed and determined for the final election notice of alteration.
As a minimum, canvassers working in the area(s) affected by an election should return any voter registration forms that they have collected as soon as possible, and by the registration application deadline for that election.
You should provide details in instructions to canvassers on how often forms should be returned to the registration office if an election occurs.
Registration application forms collected by canvassers by the registration deadline, are deemed to have met the registration deadline even if not brought to the office of the Electoral Registration Officer until after the registration deadline. Canvassing only needs to pause in the area(s) affected by the election.
Canvassers in the electoral area(s) affected by the election should, if they are not already, encourage occupiers who are not registered to do so online (or by telephone if you offer this service), and highlight the registration application deadline. They could have blank registration forms available for potential electors to complete where they do not have access to the internet.
To ensure that only forms received before the registration deadline will be processed canvassers should be instructed to suspend personal visits by the end of the twelfth day before the poll.
Publication of the revised register
Publication of the revised register
This section of the guidance covers the practical management of the publication of the revised register following the canvass, including timing, content and layout of the register, and guidance on access and supply to the register post publication.
When should I publish the revised register following the annual canvass?
When should I publish the revised register following the annual canvass?
Unless there has been an election during the canvass you must publish the revised register by 1 December.1
Dies non do not apply to the requirement to publish by 1 December which means you can publish the register on a Saturday, Sunday or bank holiday if you choose to do so. You also have discretion to publish before this date, however doing so will have an impact on the cut off dates for registration applications.
Publishing on 1 December will help to ensure that the revised register is as accurate and complete as it can be and will maximise opportunities for potential electors to be included.
Publishing in November means the revised register would not reflect any new electors who had applied to register after 23 October, nor would it reflect any amendments or deletions determined after 31 October.
While the registration process continues throughout the year, the publication of the revised register is a key milestone. Whenever you decide to publish, you should be able to explain the reasons for your decision. See the table below.
Event | Dates if the revised register is published on 1 December | Dates if the register is published in November |
---|---|---|
Last day for receipt of new applications to register | 22 November 2024 | 23 October 2024 (6 working days before the determination deadline) |
Determination deadline | 30 November 2024* | 31 October 2024 (last working day of the month prior to the month when the revised register is published) |
Anonymous registration application and determination deadline | 30 November 2024 | 31 October 2024 (last working day of the month prior to the month when the revised register is published) |
Deadline for amendments to and removal of register entries | 30 November 2024 | 31 October 2024 (last working day of the month prior to the month when the revised register is published) |
Publication | By 1 December 2024 | Any date during November |
*as 30 November is a non-working day, you could use the 29 November as the determination deadline for publication of the revised register on 1 December.
Monthly notices of alteration
Updates to the register must be published on the first working day of each month, however you are not required to issue a monthly notice of alteration in the month you are publishing the revised register or in the two months before that day, but may do so if you wish. If the register is published in November this means you are not required to publish a monthly notice of alteration in September, October and November. If it is published in December, you are not required to publish a monthly notice of alteration in October, November and December.
- 1. Section 13(1) Representation of the People Act 1983 ↩ Back to content at footnote 1
What does the revised register contain when published?
What does the revised register contain when published?
The full register
You must publish a full register of electors combined as far as possible into one register for all election types, and containing the appropriate franchise markers.
The format of the register is not prescribed but must contain, with the exception of certain special category electors, and the details of any person under 16 years old,1
the name, address and elector number of every eligible elector whose application to register has been determined by the relevant deadline, including attainers.2
An attainer is someone who is not yet old enough to vote but will achieve the required voting age for certain types of polls by the end of the twelve months following the 1 December after the relevant date.
The local government register will include 16 and 17 year olds as full electors.3
Additionally, 14 and 15 year olds are entitled to be included on the local government register as attainers.
The combined register will need to make clear the date on which those included on it will become old enough to vote in different elections to clearly show when they will become eligible to vote.4
Your revised register must include all additions and amendments to the register which you have determined by the relevant deadline.5
Only when an application has been made and successfully determined can an individual be added to the register. Information provided in response to a canvass communication and any names identified through checking local records cannot be treated as an application to register or be added to the register.
You should also ensure you action any deletions that you have determined since the publication of the last notice of alteration in the revised register.
The edited register
An elector’s name and address will be included in the edited register unless they ask for them to be removed.
You must publish a revised edited register which is an exact copy of the full register, but excludes those who have opted out of their details appearing, at the same time as you publish the revised full register.6
Any person under 16 years old is automatically opted out of the edited register.
In addition you must continue to publish the edited register on the first working day of every month. This duty applies all year, including during the canvass period and any requests from existing electors to change their opt-out status will need to be reflected.
However, if you choose not to publish notices of alteration in the 2 months preceding the publication of the full register following the annual canvass, any monthly revised edited register must not include or remove any details of any electors that are not already existing electors previously included on the full register or any alteration notice.7
You are required to publish a fully integrated updated version of the edited register rather than a notice setting out the changes.8
However, you do not have to print a full edited register every month, only if you are producing one for somebody who has requested it.
For more information see our guidance on processing a change to an elector’s edited (open) register preference.
No information on those aged under 16 must be included on any version of the register published or otherwise made available, including the edited register, except in very limited circumstances.
Describing the full and edited registers
The terms ‘full register’ and ‘edited register’ are the technical terms used in the legislation. The terms ‘electoral register’ and ‘open register’ have to be used to describe the full and edited register to members of the public, to make it easier to understand the purpose of each register and how it is used. In specific instances where we mention the edited register in the guidance in this context, we refer to the edited register as the ‘open register’. Otherwise we use the term ‘edited register’.
List of overseas electors
You must keep a separate list or lists of overseas electors.9
You must publish this and make it available for inspection and supply when you publish the revised register.10
The list must be compiled in alphabetical order by surname within each constituency or part of a constituency within your area.11
It must specify both the qualifying address and the full address outside the UK of each overseas elector.
- 1. Section 13(1) Scottish Elections (Reduction of Voting Age) Act 2015 ↩ Back to content at footnote 1
- 2. Section 9(2) Representation of the People Act (RPA) 1983 ↩ Back to content at footnote 2
- 3. Section 4(5)(a) RPA 1983 ↩ Back to content at footnote 3
- 4. Section 9(5A) RPA 1983 ↩ Back to content at footnote 4
- 5. Section 13(2) RPA 1983 ↩ Back to content at footnote 5
- 6. Regulation 93(1) Representation of the People Regulations (Scotland) (RPR) 2001 ↩ Back to content at footnote 6
- 7. Regulation 93(2) RPR 2001 ↩ Back to content at footnote 7
- 8. Regulation 93 RPR 2001 ↩ Back to content at footnote 8
- 9. Regulation 45(1) RPR 2001 ↩ Back to content at footnote 9
- 10. Regulation 45(3) RPR 2001 ↩ Back to content at footnote 10
- 11. Regulation 45(2) RPR 2001 ↩ Back to content at footnote 11
Format of the revised register
Format of the revised register
When creating the layout of the register you must:
- divide the register into polling districts
- give each polling district a unique set of letters, or numbers, or combination of letters and numbers1
- give a number to each elector2
The elector numbers should be allocated sequentially in each part of the register. The polling district letters and the number together are known as the elector number.
We have produced separate guidance on undertaking reviews of polling districts, polling places and polling stations.
Entries in the register for each ordinary elector must be arranged in street order and may only be arranged in alphabetical order by name or a mix of the two where it is not reasonably practicable to list them in street order.3
Franchise markers
Some electors may only vote in certain types of elections and their names must be prefixed in the register with certain letters:4
Letter | Elector |
---|---|
F | is an overseas elector who is only entitled to vote at UK Parliamentary elections. |
M | is a qualifying foreign national (except a citizen of a Commonwealth country or the Republic of Ireland) or a prisoner serving a sentence of 12 months or less, who is entitled to vote at local government and Scottish Parliamentary elections. |
L | is a peer who can sit in the House of Lords, who is entitled to vote at local government and Scottish Parliamentary elections |
Attainers
Some electors added to the register will be known as attainers. These electors are individuals who have not yet reached voting age but will do so before the next expected publication of the full register for some polls. 14 and 15 year olds are entitled to be included on the local government register as attainers. A date will be given after these electors’ names to indicate when they will have attained the age where they can vote.
Other electors
There must be a section after the ordinary electors in any polling district marked 'other electors', containing any special category electors who are not listed in the main body of the register listed by surname in alphabetical order without an address, followed by any anonymously registered electors.5
Our guidance on special category electors sets out in detail how special category electors should be included on the register.
We have produced a resource showing an example of how the register should be formatted.
- 1. Regulations 38 and 39 Representation of the People (Scotland) Regulations (RPR) 2001 ↩ Back to content at footnote 1
- 2. Section 9(3) Representation of the People Act 1983 ↩ Back to content at footnote 2
- 3. Regulations 41(1) and (2) RPR 2001 ↩ Back to content at footnote 3
- 4. Regulation 42 RPR 2001 ↩ Back to content at footnote 4
- 5. Regulation 41(3) RPR 2001 ↩ Back to content at footnote 5
Communication activity following the publication of the revised register
Communication activity following the publication of the revised register
Publication of the revised register could prompt enquiries to you, which you should be prepared to respond to.
You should consult with your local authority press or communications teams if you haven’t already done so to ensure that you are able to react quickly to any local stories that may emerge, particularly if there has already been local coverage on any electoral registration issues in your area.
You should consider issuing a press release announcing the total number of people registered in your area, highlighting the work you have done and any additional work you have planned to get people registered.
You should point out that there is still an opportunity to register in time for the next scheduled elections, using it as a call to action for anyone in your area who is not yet registered to do so.
Given the continued media focus on the registration rates of students and attainers, you might find it helpful to highlight the work you are doing with schools, colleges, universities or any relevant voluntary groups to encourage registration.
Your press team can get further advice by contacting the Electoral Commission press office on 020 7271 0704, or by emailing [email protected].
What data will I need to collect and share following the annual canvass?
What data will I need to collect and share following the annual canvass?
The Ministry of Housing, Communities and Local Government may request management information each year following the annual canvass; the required information may also change from year to year, however your EMS should be able to produce reports to support these requests.
Electoral Commission Canvass Data Collection
Each year the Electoral Commission will request data following the publication of the annual register. The data to be provided will be contained in reports which will be generated fully populated in your EMS system. The Research Team at the Commission will work with your EMS provider to specify the reports ahead of the data collection and your EMS supplier should let you know how to generate the correct report from the system.
Once you have generated the report in your EMS system and reviewed the data, please submit it to [email protected] as soon as possible after the publication of the annual revised register. Deadlines for submission and further information will be communicated via an EA bulletin.
Performance standards
While we will still want to collect data from all EROs to help us understand the state of the electoral registers across Great Britain, we are not proposing that EROs would routinely collate and provide us with all the information listed within the standards. You should however use the data and qualitative information set out in the standards to help understand the impact of your activities to identify what works and what doesn’t and where improvements can be made. The framework and supporting tools and templates are designed to support this analysis and focuses on the key data and information that will indicate what is working well and what is not working so well.
RPF 29
Each year the National Records of Scotland will issue an RPF29 form to EROs which you are required to supply to the Secretary of State, Scottish Ministers and the Registrar General of Births, Deaths and Marriages for Scotland,1 setting out certain prescribed information relating to the revised register.
You are required to submit this information as soon as possible after publication of the revised register.2
- 1. Regulation 44 Representation of the People (Scotland) Regulations (RPR) 2001 ↩ Back to content at footnote 1
- 2. Regulation 44(1) RPR 2001 ↩ Back to content at footnote 2
Who can be supplied with the register?
Who can be supplied with the register?
Access to and supply of the full electoral register is limited to those prescribed in legislation.
You have a duty to supply free copies of the register of electors to various organisations and individuals, and legislation imposes restrictions on how this is done. In some cases, registers have to be supplied on publication and in others the register is only supplied on request.
The timing of receipt of the register is particularly important to some recipients. For example, political parties need the electoral register to fulfil their statutory obligations in relation to the checking of donations, in addition to using it for campaigning purposes. It is important that the register is supplied promptly and you should, therefore, supply the register to anyone who is entitled to receive it on publication as soon as possible and in any case, within 5 working days.
You should ensure that every person/organisation that receives the register, whether on publication, by sale, or on request, is aware that:
- they must only use the register for the permitted purpose(s) specified in the Regulations
- once the purpose for which the register has been supplied has expired, they must securely destroy the register
- they understand the penalty for misuse of the register
You should not provide any advice in response to questions about whether a recipient’s proposed usage of register data is in accordance with the law. It is for the recipient of the register to be satisfied that their use of the register is in accordance with what the law sets out. If they are not certain they should speak to the Information Commissioner’s Office (ICO) or seek their own legal advice.
We have made cover sheets available, which set out how the register may be used and the penalty for misuse, for the sale and supply on request and inspection of the electoral register.
We have also produced a list of people entitled to be supplied with the electoral register.
There are different provisions that apply in respect of the edited register and the marked register.
To demonstrate that you are complying with the principles of processing personal data, ensuring that it is processed lawfully, fairly and in a transparent manner you should maintain records of every person and organisation you supply with the register.
We have produced further detailed guidance on access and supply of the electoral register throughout the year.
Data relating to those under 16 years of age
Data relating to those under 16 years of age
Data relating to those under 16 years of age can only be accessed by, or made use of by, EROs and their staff. No version of the register or any absent voting lists published or otherwise made available should contain that data.
However, the data may be disclosed: 1
- to the individual themselves (including disclosure of the data to demonstrate that they are a permissible donor) or to a person they have appointed as proxy to vote for them
- for the purposes of a criminal investigation or criminal proceedings relating to the registration of electors or the conduct of elections
- in a communication sent to an individual or household for the annual canvass, although the date of birth must not be pre-printed.
- to EROs and Returning Officers in connection with the registration of electors or the conduct of elections
The only other exception is that before a Scottish Parliamentary or local government election, the information on those under 16 years of age who will be eligible to vote at the election (i.e. will attain the age of 16 on or before polling day), can, for the purposes of or in connection with the election, be disclosed in the electoral register, postal voters list, list of proxies and list of postal proxies, that is supplied to:2
- candidates at Scottish Parliamentary and local government elections for electoral purposes or to comply with the rules on political donations
- the Returning Officer for the purposes of Scottish Parliamentary or local government elections
- the Electoral Commission. In this case, the Commission is only allowed to use the information in connection with its functions relating to donation controls and publication of information for certain functions including those relating to donors, but the latter does not enable publication of the names and addresses of those under 16 years old
- a local authority Returning Officer only for the purposes of a National Park authority election
The information supplied before an election must not contain anything that would identify a voter as under 16 years old.
No other individuals or bodies may be supplied with any information relating to those aged under 16 years old.
- 1. Section 14 Scottish Elections (Reduction of Voting Age) Act 2015 ↩ Back to content at footnote 1
- 2. Sections 14(3) and (4) Scottish Elections (Reduction of Voting Age) Act 2015 ↩ Back to content at footnote 2
Notifying anonymous electors about replacement Anonymous Elector's Documents
The elector number of an anonymous elector may change when you republish the electoral register following the conclusion of the annual canvass.
If an anonymous elector’s electoral number has changed and they have an Anonymous Elector’s Document, you must notify them that their electoral number has changed, that their Anonymous Elector's Document is no longer valid and that you will issue them with a new Anonymous Elector's Document.
For more information see our guidance on Replacement of an Anonymous Elector's Document where the elector number has changed.
Elections immediately following the canvass
Elections immediately following the canvass
This section of the guidance covers considerations for an election held in December following the conclusion of the canvass and the publication of the revised register. It includes guidance on which register you should use for a December election and how this will impact on candidates and political parties and on the production of poll cards.
What do I need to consider for a December election?
What do I need to consider for a December election?
For any election held in December, the notice of election will be published before the deadline for publishing the revised register.
Impact on candidates and political parties
The nomination of candidates is based on the register in force on the last date for publication of the notice of election. If you have published your revised register by the last date for publication of the notice of election, this will be the register candidates and agents need to use for collecting subscribers. If not, it will be your last published notice of alteration.
You should ensure that candidates and their agents are aware of which register to use when collecting subscribers for the purpose of completing their nomination papers.
It is particularly important that candidates and parties who have requested a copy of the revised register and election notices of alteration are provided with copies as soon as possible after publication. This will assist candidates and political parties to engage with electors and campaign effectively where the publication of the revised register takes place during an election period.
Poll cards
Returning Officers (ROs) must send poll cards to electors entitled to vote at the election as soon as practicable after publication of the notice of election.
You may wish to take this into consideration when deciding whether or not to publish the monthly notices of alteration during the annual canvass period. If you are the ERO for an electoral area that crosses local authority boundaries, you should liaise with the other ERO(s) and RO(s) in reaching your decision.
Choosing to publish these additional notices may help to mitigate any renumbering issues caused by the publication of revised registers after poll cards and postal votes have been issued.
If you choose not to publish the monthly notices of alteration during the canvass period, poll cards sent before the publication of the first interim election notice of alteration will be based on data which would not reflect any additions or deletions determined after the deadline for the September monthly update.
In these circumstances there is an argument that the earliest point it would be practicable to issue poll cards would be immediately following the publication of the first interim election notice of alteration so that the data used reflects additions and deletions determined during the canvass period.
If you are not also the RO, you should work with them to put mechanisms in place to ensure that poll cards can be sent to electors as soon as possible after the first interim notice has been published. See our guidance on election notices of alteration and the deadlines for applications to be made for inclusion on those notices.
ROs need to make clear in polling station staff training that the elector numbers on poll cards may be different to the numbers allocated to electors when the register is revised. They should explain that this does not affect a person’s entitlement to vote and that they should not refer to the elector number printed on the poll card when marking the register and completing the corresponding number list.
Instead, when the elector provides confirmation of their name and address, use the number as it appears against the elector’s details in the polling station register for completing the corresponding number list.
Polling station staff should be briefed so they are able to respond to any queries from electors who may question why the number being read out and written on the corresponding number list is different to the one which is printed on their poll card.
What is the impact on a December election if the final election notice of alteration is published before the revised register?
What is the impact on a December election if the final election notice of alteration is published before the revised register?
In some cases an election in early December will require the final election notice of alteration to be published before the revised register.
Where this is the case the registration application deadline will be the deadline for applications for inclusion on the revised register. This is because the revised register has immediate effect and will apply to any poll on or after publication.
While the registration application deadline for inclusion on the final election notice of alteration will be twelve working days before the poll, where the revised register is published after the final election notice of alteration potential new electors will be able to submit a registration application until the deadline for inclusion on the revised register (six working days before the determination deadline).
Provided their application is determined by the determination deadline for the revised register (which is the working day before publication) they will be entitled to vote in the poll.
However, potential new electors wishing to vote by post will need to have applied to be registered by the postal vote application deadline which is 5pm eleven working days before the poll as they must state an address at which they are or have applied to be registered in their postal vote application.
Potential new electors who wish to vote by proxy will have the same registration application deadline as those voting in person. This is because the deadline for registration applications to be made in time to be included on the 1 December register will be before the ordinary proxy application deadline (5pm six working days before the poll).
These circumstances will present a number of administrative challenges for EROs and ROs. If you are not also the RO, you will need to liaise with them to:
- discuss any practical implications, including the timely transfer of data
- supply candidates and agents with copies of relevant electoral registers for nomination and campaigning purposes in a timely way
- make arrangements to supply the first interim notice of alteration and any subsequent updates to candidates and agents as soon as possible once published
- produce polling station registers after publication of the revised register
- make arrangements for registers to be printed and collated in a limited time - ROs will need to consider how to manage the preparation of ballot boxes to facilitate this
The specific challenges and solutions will vary depending on local circumstances. If you would like any further guidance or would like to discuss your particular situation, please contact your local Commission team.
Which register should I use for an election in December following the publication of the revised register?
Which register should I use for an election in December following the publication of the revised register?
There is no provision to postpone publication of the revised register as a result of an election that will take place after the 1 December.
The revised register has immediate effect on publication for all elections, this is unlike a notice of alteration which only has effect at an election if published on or before the fifth working day before the poll.
Once you have published the revised register it will be used for polling purposes for any election with a polling day on or after the date of publication, although you are also required to publish two interim election notices of alteration and a final notice of alteration on the fifth working day before the poll.1
The nomination of candidates for a UK parliamentary election will be based on the register in force on the last date for publication of the notice of election.
- 1. Sections 13AB and 13B Representation of the People Act 1983 ↩ Back to content at footnote 1
How should I evaluate the success of the annual canvass?
How should I evaluate the success of the annual canvass?
As part of your planning for delivery of the canvass, you will have established how you will evaluate the overall success of the canvass to inform your plans for future canvasses. Over time, your evaluation and refinement of your plans should ensure that your canvass processes make the best use of resources, are successful in encouraging households and individuals to take the necessary action, provide the best service for electors and reduce the administrative burden on your service.
Your evaluation should utilise the metrics available to you via your EMS system. The performance standards for EROs, and the tools and templates available to support them, will assist you in understanding the impact of your activities, help identify where improvements can be made and support you to report on your own performance locally.
You should use the data and qualitative information set out in the standards to help understand the impact of your activities, both throughout and at the end of the canvass, to identify what works and what doesn’t and where you can make improvements. The framework is designed to support this analysis and focuses on the key data and information that will indicate what is working well and where improvements could be made.
What are the data protection considerations for an Electoral Registration Officer?
What are the data protection considerations for an Electoral Registration Officer?
Electoral Registration Officers must consider data protection issues in many aspects of their work.
Our guidance covers your role as a data controller, how you should protect the personal data you hold, how long you should retain it for, and where you can find more information and guidance on data protection legislation.
Who is a data controller?
Who is a data controller?
As ERO, you are a data controller with a statutory duty to process certain personal data to maintain the electoral register. Under data protection legislation you need to be able to demonstrate that you comply with the principles of processing personal data, ensuring that it is processed lawfully, fairly and transparently.
Advice from the ICO is that all data controllers need to ensure that they are registered with the ICO. This means that EROs and ROs must be registered separately to their council.
Under the data protection legislation, a public authority must appoint a data protection officer (DPO) to advise on data protection issues. As ERO or RO, you are not included in the definition of a public authority contained in Schedule 1 to the Freedom of Information Act 2000 and are not required to appoint a DPO for the conduct of your duties. However, your appointing council must have a DPO in place and you should liaise with them over good practice in relation to data protection.
A key element of data protection legislation is the increased focus on accountability and transparency when processing personal data. You must be able to demonstrate that you comply with your obligations under data protection legislation. The key to achieving this is to have and maintain written plans and records to provide an audit trail.
Our resource on data protection legislation details how you can put measures in place to meet the requirement to demonstrate compliance and to ensure that data protection is integral to all you do.
You need to ensure that you are complying with your responsibilities under data protection legislation. In particular, you should ensure that you:
- are registered with the ICO as a data controller
- have appropriate privacy notices in place
- are retaining documents in accordance with your document retention policy
- ensure that data protection is integral to any contracts where personal data is processed
- have a policy document in place to process special categories of personal data
- maintain records and plans to demonstrate that you are processing personal data lawfully, fairly and in a transparent manner
- in your plans and risk register, highlight the safeguards you have in place to avoid a personal data breach
Guidance on demonstrating compliance with data protection legislation is contained throughout our data protection guidance for EROs and ROs.
How should I protect the personal data I hold and how long should I retain it for?
How should I protect the personal data I hold and how long should I retain it for?
You will need to check that appropriate security measures are in place to protect personal data. You should review your processes with your data protection officer and information management/IT departments to help identify any risks to the security of the data you hold, whether on paper or stored electronically.
You need to maintain a document retention policy, which will help demonstrate that you are complying with the principles of processing personal data, ensuring that it is processed lawfully, fairly and in a transparent manner.
Your document retention policy should set out the following for all documents you receive and hold:
- whether the document contains personal data
- the lawful basis on which any personal data was collected
- your retention period
- your rationale for the retention period (which might relate to a requirement in electoral law)
Our data protection guidance for EROs and ROs contains further guidance on the retention and storage of documents, including what information your document retention policy should contain.
You will be collecting personal data from residents such as date of birth, nationality and their National Insurance Number. Your council will have corporate standards and processes for handling data and security. You should seek advice from your Data Protection Officer and IT about maintaining effective data handling. They will be able to help you identify any risks to the security of the data you hold, whether on paper forms or stored electronically on your systems.
You will need to ensure that your procedures and storage arrangements are compliant with data protection legislation. Good data handling practices need to be part of your day-to-day business processes. For example, you will need to keep under review how you are managing the security of personal data.
What do I need to consider when storing email addresses and phone numbers
Where a response to a canvass communication contains individuals’ email addresses and/or telephone numbers you should ensure that these are recorded, in accordance with data protection legislation requirements, and that this information is only used for the purpose for which it was collected.
If you have existing records of email addresses or phone numbers, at the time that you next use that information, you should ensure the data subject is aware of how you will continue to process this data such by:
- explaining the data subjects right to object to further processing
- providing a link to your privacy notice
- including an unsubscribe option
More information on the provision of an unsubscribe option can be found in our data protection guidance for EROs and ROs.
Where can I find more information and guidance on data protection legislation?
Where can I find more information and guidance on data protection legislation?
You can find guidance on data protection on the Information Commissioner’s website, or if you have any specific questions you can contact the Information Commissioner’s Office directly.
Information Commissioner’s Office – Scotland
45 Melville Street
Edinburgh
EH3 7HL
Tel: 0303 123 1115
Email: [email protected]
The Local Government Association/ SOCITM have also produced guidance for local authorities on data handling (although it should be noted that the ERO is a separate data controller from the local authority). It recommends that you consider the following factors when developing your approach to data handling:
- Policy: comprehensive policies (including business continuity, and home and mobile working) should form the information governance regime. The policies should be monitored and audited to ensure they are being effectively enacted
- People: including staff awareness and training, users’ access, and mechanisms for managing information risks
- Places: including risk assessments, security of buildings and premises, the disposal of information, and use of removable media
- Processes: including who can access data, system security, transfer of data, and supplier and contractor data processes
- Procedures: including risk reporting, auditing procedures, and documented policies and procedures
Resources for Electoral Registration Officers
Ministry of Housing, Communities and Local Government resources for Electoral Registration Officers