Guidance for the GLRO administering the GLA elections
Managing the risk of electoral fraud and the security of the election
You should lead on putting in place a single integrity plan for the whole of Greater London that covers the specific steps you will take to identify and deal with any potential electoral fraud or security concerns and how you will communicate your approach to provide confidence in the elections process to all stakeholders. You should do this in discussion with the police and CROs/BROs, ensuring that CROs' integrity plans do not conflict with your own plan for the London-wide area.
Voters and campaigners should be confident that elections are free from fraud, everyone can safely take part in the election process and that the results you declare are a true and accurate reflection of the will of the electorate. Trust and confidence in the integrity and security of elections is essential but can be fragile – it will be difficult for you to rebuild trust or confidence which has been lost as a result of allegations or proven cases of fraud. It is also vital that candidates and campaigners can participate free from intimidation or risk.
Planning for the prevention of electoral fraud and safe delivery of electoral events
While you will need to be able to work with the police, including your police Election Single Point of Contact (SPOC), Force Elected-Official Adviser (FEOA), and prosecutors to investigate any allegations which might be made, you should also put in place effective strategies for managing the safe delivery of electoral events and the prevention of electoral fraud from the outset.
In order to ensure that voters and candidates can have confidence that votes will be cast and counted in the way voters intended, you will need to have in place plans and processes to identify any patterns of activity that might indicate potential electoral fraud. You should review any mitigations for specific risks that you have identified regularly.
You should establish and maintain contact with the police at an appropriate level as part of this. The police Election SPOC officer will be able to provide you with contact details for the relevant force command or lead unit and will also be able to explain any divisional structure within the force if appropriate. You should ensure that you are provided with the contact details of any divisional Election SPOCs and FEOAs and ensure that the CROs schedule regular contact with them.
Your plan should be developed in consultation with your Election SPOC. The Election SPOC is your contact for election-related crime, including allegations of fraud. The FEOA is a dedicated police contact for raising security concerns and sharing any relevant intelligence involving any elected officials and candidates for those roles. For more information see our guidance for CROs on working with your local police force.
Your plans should include specific steps to maintain the security of the elections and identify and deal with any potential electoral fraud, and should also identify how you will communicate your approach to maintaining electoral integrity in order to support public confidence in the election.
You should plan how you will share candidate contact details (such as email addresses and telephone numbers) with the FEOA to enable them to contact candidates and agents directly with updated security guidance. You should review your data protection policies and privacy notices to ensure these are fit for purpose. For more information, see our guidance on the lawful processing of personal data.
Integrity plans prepared by CROs should fit within the London-wide plan and include any issues they have identified locally. Guidance for CROs on integrity plans can be found in our guidance for CROs. You should ensure that you have considered the specific risks relating to each constituency, including taking into account previous allegations of electoral fraud. There are a number of electoral offences specified in electoral law and the College of Policing Authorised Professional Practice has produced information on these offences and how they will be investigated.
You should discuss your plans with your Election SPOC at the earliest opportunity. A checklist of topics that should be considered at any pre-election planning meeting between you and your Election SPOC is available. You should, as part of this meeting, consider the possibility of any joint publicity work that can be carried out with the police, for example, jointly running public awareness campaigns within the electoral area to highlight what can be done to help detect and prevent electoral fraud.
Your plans should include specific steps to deal with any safety concerns throughout the process, such as:
- If there is an immediate and direct threat to personal safety and/or the incident is currently ongoing and urgent, the candidate and/or their staff or family should call 999 as a priority.
- If the incident does require an urgent response but is not currently ongoing or an immediate threat, it is important to use the 101 service or Contact us | Police.uk (www.police.uk).This is the easiest and quickest way to record incidents and obtain the allocation of appropriate resources and gain a reference number.
- Neither the FEOA, nor Election SPOC, is the right person to contact to record these incidents and may not be even on duty when they occur. They will be notified though, via internal processes. Both of these Officers will be aware of the incidents and the Election SPOC may well manage crimes of election fraud, but this is not part of the FEOA role.
Your plans should also cover specific steps to deal with any potential electoral fraud such as:
- an agreed approach for referring allegations of fraud for further investigation where appropriate
- establishing a process for handling evidence, so that the police can carry out any forensic analysis
- any specific risks you have identified in addition to any general fraud detection plans
In particular, you should agree with your Election SPOC an approach for referring security concerns or allegations of fraud you may receive for further investigation where appropriate. For example, will you or the CROs be the initial point of contact and refer allegations to the relevant Election SPOC, or will the relevant Election SPOC be the initial point of contact and advise you of allegations? In addition, you should agree a mechanism for handling evidence, so that the police can carry out any forensic analysis, where necessary.
A template memorandum of understanding between CROs and the police on joint planning for elections and the reporting and investigating of electoral fraud is available on the College of Policing Authorised Professional Practice website. Elements of this document can also be adapted for any memorandum of understanding between you and the police.
You should also share the approach to maintaining the security of the election and tackling electoral fraud with parties, candidates and agents at briefing sessions and/or within the information provided to them. You should also invite the police to attend any such briefing sessions and invite them to supply you with any relevant documentation to include in your information pack.
Following consultation with ROs, police forces and political parties, the Commission has issued a Code of Conduct for campaigners at elections and referendums.
The Code applies to all campaigners, and sets out agreed standards of appropriate behaviour before and during an election or referendum. The Code also makes it clear that if a Returning Officer considers it appropriate to address further specific local risks, and has consulted with relevant national and local parties, we will support them in introducing additional local provisions which go beyond the terms of the nationally agreed Code.
The College of Policing Authorised Professional Practice have developed a template letter seeking agreement from candidates to abide by the Code of Conduct and this should be provided to all candidates standing at the election.
In some cases, where there is a significant risk of electoral fraud allegations or to the safe delivery of electoral processes you should also consider communicating your approach to tackling fraud or addressing security concerns more widely in advance of polling day to provide reassurance to voters and campaigners.