Running electoral registration - Wales

You are not limited to using the match result to decide whether the identity of the applicant has been established. 

You can use local data to either:

• verify an applicant's identity where an applicant has been unable to provide a NINo, provided that you are satisfied the reason given for not providing a NINo is valid 
• verify applicants whose personal identifiers fail to be matched against DWP records1 where you have sent the details of an application to DWP upon receipt,2 and have received and considered the match results3  

Matching against local data allows you to use data sources available to you to verify that the person making the application is who they claim to be. 

Where you make an assessment which does not accord with the match result (for example, local data which contradicts the DWP match result), you should record the reasons why you have reached your assessment and the evidence used.

Where a person aged 14 or 15 years old makes an application, it will not be sent for verification against DWP records and so you will not receive verification results. Instead, you will need to verify the application using education records.

Deciding whether to use local data for verification

The use of local data for identify verification is not compulsory. Your decision on whether to use local data matching should be taken after consideration of the benefits that local data matching can have in terms of reducing the burden on the applicant to provide evidence and follow-up costs.

Before using local data to inform the determination of an application, you must ask the following questions:4  

• what sources of local data are available to me?
• is the data record I intend to use accurate?
• what benefit will I gain from using local data matching for a particular task?
• what resources will I need to be able to use local data effectively?
• what are the costs involved in developing/using local data matching capacity?
• can I achieve beneficial results in sufficient time to meet the needs of the task?

You may decide that the local data sets available cannot be used to verify the identity of the applicant or that directing the applicant to the exceptions or attestation processes would be a more effective way of establishing identity.

Potential data sources for local data matching

You can require any person to supply you with information required for the purpose of determining an application for a Voter Authority Certificate or Anonymous Elector’s Document.5 You are therefore entitled to request data sets from organisations where you deem it necessary for the purpose of verifying the identity of an applicant.

There are a wide variety of data sources that may be available including, but not limited to:

• housing and council tax data
• adult social care data
• local authority billing and payments data
• parking permits data
• school admission data
• blue badge data
• customer service records
• payroll data
• registrar data on births, deaths, and marriages

As ERO, you are legally entitled to access local data sets and to inspect and make copies of records kept in whatever form by:6  

• any person, including a company or organisation, providing services to, or authorised to exercise any function of the council; this includes those providing outsourced services under any finance agreement. For example, a private contractor appointed to collect council tax on behalf of the local authority
• any registrar of births, deaths, and marriages, including any superintendent

Legislation gives express permission for local authorities who have not directly appointed an ERO to provide data to the ERO but requires a written agreement between the ERO and the authority to be in place before any transfer of data occurs.7 The written agreement should address the processing of information including its transfer, storage, destruction, and security.

While you have a legal entitlement to your local authority’s data, you should conduct any data matching activities in accordance with current data protection legislation, relevant guidance and good practice available on the Information Commissioner’s Office website.