What records can you inspect to assist you with identifying potential new electors throughout the year?

Your registration plan should include detail of data sources available to you and a schedule of when checks of those records are to be carried out. 

As ERO you can by law, for the purpose of meeting your registration duties, inspect and make copies of records kept in whatever form by:1  

• the council which appointed you
• any registrar of births, deaths and marriages including any superintendent 
• any person, including a company or organisation, providing services to, or authorised to exercise any function of, the council including any providing outsourced services under any finance agreement 

Where the ERO requests to inspect and/or take copies of the records listed above, a statutory or other restriction, including the GDPR, cannot be used to refuse disclosure of those records.2  For example, if a private contractor has been appointed to collect council tax on behalf of your local authority, as ERO for that authority, you are entitled to access the data held by that contractor.

In addition to this, the council which appointed the ERO is permitted to disclose to the ERO, for certain registration purposes, information contained in records held by the council.  

There are three purposes:

• to verify information relating to a person who is registered in a register maintained by the officer, or who is named in an application for registration
• to ascertain the names and addresses of people who are not registered but who are entitled to be registered
• to identify those people who are registered but who are not entitled to be registered

Disclosure can only be made in accordance with a written agreement between the council and the ERO processing of the information, including its transfer, storage, destruction and security.

You should also ensure that you are making full use of all the records available to you to check entries on the register, taking steps to remove those electors who are no longer entitled to remain registered.

You should record the number of electors removed from the register and the reason for the removal.

For more information on what types of other records can also be used to identify changes and those who may no longer be entitled to be registered at a particular address see our guidance on managing amendments, reviews, objections and deletions throughout the year.

You will need to use information sources available to identify and target new electors, and ensure that all necessary steps are taken to add them to register.  

While records may assist you in identifying who does not have an entry in the register, any potential new elector who is identified must always make a successful application before they can be added to the register. You should record the number of electors added to the register and how these applications originated. For example, whether the application was unsolicited or was it following information included in a canvass communication.

The following records may help you maintain your register throughout the year: 

• Council tax: These records may indicate new residents have moved into a property. However, the person named on council tax records is not always eligible to register to vote, for example owners of properties that do not reside there. Also, council tax records will not necessarily tell you all of the people resident at the address who you may need to invite to register. Council tax records can be used as evidence that a property is empty or that it is not someone’s main residence, which may affect their entitlement to register. Access to these records should include any supplementary notes, which may assist with clarifying who is resident.
• Council tax reduction (formerly council tax benefit): These records may alert you to others living at a property. 
• Housing: The records of arms-length management organisations and housing records where the council maintains the housing stock can be inspected for tenants details.
• Housing benefit: Housing benefits are paid directly to an individual and as such can be helpful in identifying new electors.
• Register of households in multiple occupation (HMOs): You should consider using these records to make contact with landlords or managing agents who are likely to be able to provide names of new residents. 
• Records held by registrars of deaths and marriages: Information received about marriages and civil partnerships could indicate an additional resident at a property. It may also alert you to a change of name of an existing elector. Or in the case of deaths indicate where an existing elector may need to be removed.
• Lists of residential and care homes / shelters / hostels: Social services (or equivalent department) will be able to provide lists of residential and care homes, as well as shelters and hostels. Wardens of these accommodations may be able to provide information on changes of residents. We have produced a factsheet for care homes in that you can adapt to reflect your particular circumstances.

The factsheet is based on our assisted applications guidance which details what one person can do to support another to register.

• Lists of disabled people receiving council assistance: Social services (or equivalent department) may be able to provide details of certain disabled people living at home, such as those who are blind, deaf, etc., which should also enable you to tailor the service you provide to such individuals.
• Land Registry: Can be used to find information on sales of property, which can provide information on changes, particularly as the name of the buyer is given.
• Planning and building control: Inspection of building control records and liaising with house builders can give an indication of the progress of new developments and whether they are ready for residential occupation. Instead of liaising with planning and building control directly, you may be able to gain the necessary information from the Valuation Office.
• List of new British citizens held by the registrar: The registrar will have information on who has become a British citizen. You are entitled to inspect and make copies of these records, and could use them to identify potential new electors. Information on applying to register to vote could be given to the registrar to include packs they make available to those receiving British citizenship. Depending on their previous/other nationality, someone who has become a British citizen may already be on the electoral register, but information should be provided in any case to ensure that they have the correct franchise.
• Local authority education data: This data may provide information to assist with the identification of potential electors aged 16 to 18 years who may be eligible to be registered as attainers or electors.

You separately have the power to require information from a person who is not the elector. You can use this power where it is required for the purposes of maintaining the register.3   For example, you can use it to require those in charge of multiple occupation establishments or care homes to provide you with information on residents.

To comply with data protection legislation, you need to demonstrate that all information obtained complies with the principles of processing personal data, ensuring that it is processed lawfully, fairly and in a transparent manner. Therefore, you should maintain details of:

• the records to be checked
• a schedule of when those checks are carried out
• the lawful basis on which you are processing that information. For example, Section 9A places an obligation on you, the ERO, to inspect these records as part of your duty to maintain the electoral register, therefore providing the statutory basis by which you are processing that personal data the security in place to protect the data. For example, encrypting/password protecting data whenever it is transmitted, and using secure storage
• action taken on the basis of the information you have obtained
• retention and secure disposal of data (in accordance with your document retention plan)