Consultation response: Draft performance standards for Electoral Registration Officers

Summary of the consultation outcomes

We commenced a 10 week consultation on a draft framework in January 2020 with the intention that we establish a new set of standards which can be used by Electoral Registration Officers (EROs) and us throughout the year to understand and improve their performance, ensuring ultimately that registers are as accurate and complete as possible, enabling everyone who is eligible and wants to, to be able to vote.

Overall, the feedback we have received has been positive and respondents welcomed the proposed approach. On the whole, respondents agreed that the standards – with some minor amendments – along with the proposed tools and templates to be provided by the Commission, will support EROs with understanding and improving their own performance. 

However, as a consequence of the coronavirus pandemic, we recognise that not everyone who would have wanted to respond to the consultation was able to do so. 

We have therefore decided to defer finalising the standards for a year, to enable further feedback to be provided.

Although we are not formally launching the standards this year, we nevertheless still believe it is important to make them and the accompanying tools and templates available as they form a key part of our guidance and support package which aims to assist EROs with planning for and delivering well-run electoral registration services across Great Britain. We will use the draft standards to inform our engagement with EROs over the next year and will report on their effectiveness before finalising them and laying them in the UK, Scottish and Welsh Parliaments by next summer.

Background

Summary of consultation responses

Overall, the feedback we have received has been positive and respondents welcomed the proposed approach. On the whole, respondents agreed that the standards – with some minor amendments – along with the proposed tools and templates to be provided by the Commission, will support EROs with understanding and improving their own performance. Respondents also broadly welcomed our proposed approach to engaging with EROs and their teams over the course of the year.

View the latest draft of the performance standards for EROs, which have been amended to reflect feedback received during the consultation. It is these standards which will be used in 2020/21 and on which further feedback will be sought to inform the final standards to be laid in Parliaments by summer 2021.  

About the draft standards

The new standards focus on the outcomes that should be delivered, rather than the processes that are followed, with the objective of helping EROs and their teams to understand the impact of their electoral registration activities. This should help EROs to make informed decisions on what activities are undertaken, how these activities are carried out and how their limited resources can be deployed efficiently and effectively.

Whilst there was general agreement from respondents that the standards focus on the right activities, a number of respondents commented that although the consultation set out our approach to using the standards over the course of the year, there was no specific mention of registration actions impacting on the delivery of Returning Officer functions at an election, which is important in ensuring that all those who want to vote are able to do so. We have therefore now included specific reference to this as part of the standards, through the addition of the activity ‘Timely and accurate supply of electoral registers to the Returning Officer to support the conduct of elections’.

The consultation responses also illustrated some confusion relating to the outcome titled ‘Stakeholders and electors have confidence in the integrity of the electoral registers’, with the use of the word integrity being interpreted as referring to electoral integrity rather than being read in line with the wider definition as was intended. We have sought to clarify this by amending the outcome to focus on the ‘secure management of the electoral registers’ rather than talking about their integrity. On the detail of this standard, we have also now added further references on cyber security processes and maintaining audit trails of how and when data has been transferred in response to feedback, making it more explicit how important these elements are in securely managing the electoral registers. 

Concerns were also raised by a number of respondents about being able to access, provide and analyse all the data listed in the standards. We believe that access to this range of information, which builds on the data already included in the existing performance standards, will be essential to enable EROs to understand, improve and report on their performance, so have worked with Cabinet Office on a better metrics project to help ensure that this data will be available within software systems and can be easily accessed by EROs when they need it. The additional tools and templates we are providing with the standards, in particular a tool which focusses on how to access, analyse and assess data, should help EROs to make full use of the information that is available to them.

There were also some specific suggestions of additional information that could be included to help EROs to understand the impact of their activities – for example, data on the number of ITRs not responded to after the reminder and personal visit stages – and a number of these have now been added in to the standards. 

Several respondents highlighted the practical difficulties of identifying the number of additions as a result of different targeting approaches. While it will be important for EROs to use the availbale data on levels of additions and deletions to help them understand the impact of their activities, we have removed the specific reference to the ‘Number of additions as a result of different targeting approaches’ from the standards, recognising that EROs are not able to see from the information routinely available from the IER Digital Service what has driven an application to be made.

Using the standards: Electoral Registration Officers

EROs will use the data and qualitative information set out in the standards, and any other additional data or information that the ERO feels is relevant, to help them understand the impact of their activities, so they can identify what works, what doesn’t, and where improvements can be made. To help them do this, we committed to developing additional tools and templates to sit alongside the standards, including a resource on using data, key performance indicator setting guidance and a reporting template. 

Respondents welcomed the proposal for additional tools and templates to support EROs in using the standards. In addition to the tools highlighted in the consultation, respondents asked for further guidance on how to use the standards and in particular how they can measure their impact and evaluate their activities. To respond to this, we will now also develop a ‘How to’ guide on using the standards which aims to help EROs and their teams understand what each element of the standards is trying to achieve and will provide examples of what the different items of data and information we list should show them, and how these can be used to help them understand the impact of their electoral registration activities.

Our consultation also set out that whilst we recognise the benefits of EROs using targets for their registration activity locally, we remain of the view that it would not be appropriate to set performance targets at a national level, given the activities and impacts will vary significantly by local area reflecting the particular demographics and circumstances EROs are each working within. We are, however, keen to support EROs with establishing a baseline of their own performance and setting targets which take into account their specific circumstances, and will be providing guidance and resources to assist with this. In particular, several respondents highlighted that they would like to be able to use data to compare their performance with other EROs. By transparently reporting on and publishing data, we hope to be able to support this activity, and will consider further how we can help to facilitate useful comparison as part of our ongoing support and challenge work.

Using the standards: Electoral Commission

The consultation set out our proposed approach to using the standards to inform how we engage with EROs and their teams over the course of the year – not just during the annual canvass period – with the objective of working with all EROs and their teams at least once every two years, continuing to use risk assessments to help prioritise the order, frequency and intensity of our engagement.

Respondents broadly welcomed our proposed approach to engaging with EROs and their teams.One respondent, the AEA, highlighted that there will be a need for us to work closely with key stakeholders to understand where support and challenge is needed, ensuring that we capture those who need more frequent support. The risk-based approach is designed with this in mind, to help identify what level of support is required, and we continue to welcome working with others to help ensure that we identify where there are particular challenges so we can target our support and challenge as appropriate. 

Respondents also commented that when gathering information from EROs and their teams, we must be mindful of electoral cycles and other demands on the ERO, and allow sufficient time for them to submit the information required. As highlighted in the consultation, it is not the Commission’s intention that EROs would routinely collate and provide us with all the information listed within the standards; instead, we will work with EROs and their teams to analyse the data and information to help us understand their performance and identify any issues or concerns. We will, however, still want to collect data from all EROs, to help us understand the state of the electoral registers across Great Britain, but we will consider the timing and number of these requests in order to keep them as straightforward for EROs as possible.

We also set out that we intend to summarise the data and information gathered through our engagement with EROs and their teams to inform regular progress reports, rather than produce an annual assessment and summary of the performance of EROs. Through our reporting, we want to provide reassurance to the public and key stakeholders (such as political parties and elected members) that EROs are doing everything they can to ensure that everyone who is eligible and wants to vote is able to do so, and to highlight any instances where this is not the case. 

Respondents were keen that reporting should be used to report on the positive work and successes, and not to name EROs that have issues. While we remain focussed on supporting EROs to understand and improve their performance, we nevertheless have a responsibility to be transparent about where issues arise and will continue to use the standards to challenge EROs when needed, including making clear in our reporting where we find that the standards are not being achieved. We will, however, ensure that our reporting will also be used to celebrate success and share examples of good practice. More generally, we are committed to working with the AEA, SAA and Solace to look at how we can work together to most effectively identify and share good practice in electoral registration, which will be of particular importance as lessons start to emerge from the first year of operation of the reformed canvass processes, and this work is an area that respondents were keen to see us expand into. 

What happens next

While we are not seeking to finalise and lay the standards in Parliaments this year, we nevertheless want to make them available as they stand now, reflecting the fact that, with our guidance and resources, they are a key part of our guidance and support package which aims to assist EROs with planning for and delivering well-run electoral registration services across Great Britain.

We will also be publishing additional tools and resources by the end of June. These products, which include a ‘How to’ guide on using the standards, key performance indicator (KPI) setting guidance and reporting templates, aim to help support EROs and their teams with using the standards to set targets and help them baseline their performance. This will give EROs a strong starting point for using the standards in future years to understand their data and any trends or variances, and to help them identify what works and what doesn’t. 

We will use the standards in this period to help establish a picture of individual EROs’ performance during the first reformed canvass as well as to understand more generally how the new processes are operating in practice. Taking a risk based approach, we will engage with a range of EROs throughout the canvass period and into early 2021, using the standards to inform our discussions. 

To prepare, we will let EROs know ahead of the discussion the types of information that we will want to discuss with them, which will vary depending on the point in the cycle we are engaging at, to help them understand the areas we will want explore, including the data that would be useful to look at.

And whilst we will continue to report on electoral registration matters, in recognition of the fact the standards have not have not yet been laid in Parliaments, as well as recognising the wider impact of the coronavirus pandemic on the delivery of electoral registration services, we will not make any formal assessments of performance in the first year. Instead, we will use our reporting over this period to highlight the outcomes of our engagement with EROs, focussing on the activities being carried out and any trends, issues and challenges identified, as well as to draw out successes and examples of good practice. We will also continue to report more widely on the canvass as we have done in previous years, which will include an assessment of how the reformed canvass is operating in practice, which we aim to publish by the end of May 2021. 

We also intend to use this period to seek feedback on the effectiveness of the standards for understanding, improving and reporting on performance, ensuring that the standards work from the ERO perspective as well as from our perspective before they are finalised. We will gather feedback in the course of our discussions with EROs and will also seek to provide an opportunity more generally for wider input on how the standards are working.

Accessible version of the draft performance standards

Stakeholders providing feedback

Last updated: 10 June 2020
Next review: 2 June 2021