Data matching schemes to improve accuracy and completeness of the electoral registers evaluation report

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1 Data matching schemes to improve accuracy and completeness of the electoral registers evaluation report March 2012

2 Translations and other formats For information on obtaining this publication in another language or in a large-print or Braille version, please contact the Electoral Commission: Tel: The Electoral Commission 2012

3 Contents Executive summary 1 1 Introduction 13 2 Set-up and coordination 21 3 Databases and the matching process 28 4 Pilot authorities: overview and emerging issues 36 5 Data matching results: Department for Work and Pensions 44 6 Data matching results: Driver and Vehicle Licensing Agency 63 7 Data matching results: Education databases 71 8 Data matching results: Ministry of Defence 75 9 Data matching results: Citizen Account Pilot costs Conclusions and recommendations 92 Appendices Appendix A: Local authority pilot profiles 99 Appendix B: Data tables 147

4 Acknowledgements The Electoral Commission would like to thank all the staff at both the local authorities and the data holding organisations for the time and effort they devoted to these data matching pilot schemes. We would also like to thank the Cabinet Office for their assistance in the collection of data from the pilots.

5 Executive summary Background As part of the proposed shift to individual electoral registration (IER), the UK Government is exploring the extent to which the use of national public databases can help Electoral Registration Officers (EROs) improve the accuracy and completeness of their electoral registers. The Electoral Commission was given a statutory responsibility to report on the effectiveness of the data matching schemes. The schemes were based on the piloting of a range of national public databases in 2011 by 22 individual local authorities in England and Scotland. 1 Our statutory evaluation considers the degree to which data matching schemes assisted EROs in improving the completeness and accuracy of their registers; resulted in any issues around administration, time and costs; or prompted objections to the schemes. Our findings are based on the data and feedback received from local authorities, data-holders and others during the course of the pilot schemes. In February 2012 the UK Government published its response to pre-legislative scrutiny and public consultation on the IER White Paper. In the response, the UK Government indicated its intention subject to the results of the evaluation of pilot schemes and further testing to widen the scope of data matching simplify the transition to IER for 2 The UK Government indicated that rather than, as originally intended, check accuracy and to identify people who may be eligible to register to vote, and then invite them to apply to register, 3 it was now their intention names and addresses of all individuals currently on an electoral register will be matched against the data held by public bodies such as the Department for Work and Pensions information can be matched, the individual will be automatically placed onto the new IER register and would not need to take any further action to be registered 1 At the outset there was a pilot authority in Wales but they dropped out early in the process. 2 HM Government (2012) Government Response to pre-legislative scrutiny and public consultation on Individual Electoral Registration and amendments to Electoral Administration law, Cm HM Government (2011) Individual Electoral Registration, Cm

6 4 Electors whose details could not be matched in this way would be asked to apply individually and to supply personal identifiers. This proposal has not been tested by these pilots. Further piloting is needed to ensure that the advantages and disadvantages of these proposals are understood. In this report we set out some of the key questions we think need to be answered to help understand the issues. Set-up and coordination The Cabinet Office managed the overall pilot process and was also involved in the delivery of the pilots. The Commission advised the Cabinet Office throughout the set-up period, in particular on the need for a clear common framework for delivering the pilots, but the final decisions on the processes were taken by the Cabinet Office. The open application and selection process used for the pilots, and the absence of a clear, common framework, contrary to our advice, led to significant variation in the planned approaches of the pilots. This introduced challenges for the evaluation in comparing the results of the different schemes and therefore the ability to draw consistent conclusions. This also created challenges for local authorities delivering the pilots because in several cases the methodology they originally planned to use proved to be based on incorrect assumptions. The timing of the pilots, which took place alongside the annual canvass, coupled with delays to the process, put pressure on the capacity of the local authority teams involved and added to the difficulty in this evaluation of drawing firm conclusions from the pilot schemes as a whole. Local authorities reported varying levels of communication with the Cabinet Office and identified areas for improvement, including a better understanding of what data was going to be shared with them. The pilots did not follow processes, in terms of the IT systems and matching arrangements, which would be used for nationwide data 4 HM Government (2012) Government Response to pre-legislative scrutiny and public consultation on Individual Electoral Registration and amendments to Electoral Administration law, Cm

7 matching. The evaluation cannot therefore draw conclusions about how the costs of these pilots would translate to a national roll-out. The databases and the matching process Ten databases were due to be tested as part of the scheme. These were the: Department for Work and Pensions (DWP) Centric database Driver and Vehicle Licensing Agency (DVLA) Driver database Student Loans Company (SLC) database National Pupil Database (NPD) (through the Department for Education) Individual Learner Record (ILR) (through the Department for Business, Innovation and Skills) Citizens Account (CA) database (through the Improvement Service in Scotland) (MoD) Joint Personnel Administration database and Anite housing database Higher Education Funding Council for England (HEFCE) student database Royal Mail change of address database However, not all were tested to the same extent. In particular, there were difficulties in accessing HEFCE and Royal Mail data. A key component of the trials was the matching process between databases to identify people to invite to register to vote. The processes employed could not be rolled out nationally but do allow for a greater understanding of the requirements of any framework for national data matching. Two different processes were used for matching the electoral registers with the DWP data on one hand and the DVLA and education databases on the other. These different rules make it difficult to compare the results from the two processes. 3

8 Pilot authorities: overview and emerging issues There were 22 data matching pilots testing various combinations of databases. The complex nature and format of the data supplied to local authorities highlighted the need for good data management and analysis skills. Many of the pilots either had these skills available within the local authority or recruited additional staff using Cabinet Office funding. However, several did not and struggled to use the information provided. The process, as tested in these pilots, was labour intensive with significant work required to analyse the data. Those involved felt that the level of work required would not be sustainable in the future. A number of pilot authorities were able to use locally-held data to interrogate the data received from the national databases. The results of this activity suggest that there is scope for more use to be made of local data both to complement any future national data matching and to improve accuracy and completeness in general. Data matching results Department for Work and Pensions (DWP) Eighteen pilots accessed the DWP Centric database. The level of match between the electoral registers and the DWP data varied significantly between local authorities. For those areas matching the whole register it ranged from 57.6% to 82.4%. These differences are partly due to different interpretations across the pilots, in the absence of a consistent framework, of what constitutes a match but are also likely to driven by differences between the local authorities in terms of demographics. 4

9 6,573 people were added to the registers as a result of follow-up activity undertaken using names suggested by the DWP Centric database. This was 13.2% of all names followed up. The response rate for the pilot follow up was affected by whether the ass. Where it took place during the canvass, the pilot response was depressed by the fact that many of the names identified by the match registered through the canvass. The pilots highlighted crucial differences in address formats between the electoral registers and the other national databases. This meant that many records could not be matched as simple address differences were not recognised. This problem could have been significantly reduced if time had been allowed for an address cleansing exercise. The absence of a unique identifier attached to each address on the public national databases was a key issue for the pilots. These would have allowed for a more straightforward matching process for local authorities. Many of the potential new electors suggested by the match with the DWP Centric database proved to be based on out of date or incorrect information. The problems posed by this could have been reduced by the inclusion of the date when the DWP record changed something which DWP were willing to provide but were not asked to do so. The absence of nationality information meant that several pilot authorities conducted follow up with people ineligible to register. However, the scope of this issue is not clear from these pilots and will have varied depending on the demographics of the local authority area. Driver and Vehicle Licensing Agency (DVLA) Match levels between the DVLA driver database and the electoral registers were lower than between the registers and the DWP Centric database, partly because because the match process used stricter criteria. The match levels varied from 51.7% to 67.3%. this was more likely to reflect poor data currency rather than significant under-registration. 5

10 208 were added to the register as a result of pilot follow-up activity. This was 4.1% of all names followed up. Many of the responses to follow-up activity indicated the person written to was not res DVLA Driver database is not current. The DVLA data was more effective at targeting 16 and 17 year olds as opposed to the population as a whole. Education databases There were very few registrations from data matching with the Student Loans Company (SLC) database. This, and responses to the follow-up activity, support the view expressed by the SLC that the data used for these pilots (at the end of the academic year) was sometimes out of date. The National Pupil Database (NPD) and Individual Learner Record (ILR) proved effective at identifying attainers 5 in these pilots. However, while the NPD and ILR identified attainers successfully, the majority of registrations were achieved through the annual canvass, which was taking place alongside the pilots, and not in response to follow-up activity through the pilots. Under IER, unlike in the current household system, individual attainers might need to complete their own form (rather than being registered by adults in the household). It is therefore possible that the number of registered attainers will fall. The ability to use data in order to target them in this way may therefore be a more useful tool for EROs in the future. Ministry of Defence (MoD) The MoD provided limited data for these pilots. They were able to confirm that existing service voters were still resident but not provide details of potential new service voters. They also provided details of addresses occupied by service personnel in the area but this excluded barracks. 5 An attainer is a 16- or 17-year-old who will reach voting age (18 years old) during the life of a current electoral register. 6

11 There was therefore no real prospect of addressing the completeness of service voter registrations in the pilot areas. Two pilots were able to use the MoD data to improve the accuracy of their register and amended or deleted a number of their records (9.6% and 13.2%) of the total number of service voters held on the register. Citizens Account (CA) The CA database is administered by the Improvement Service in Scotland and is intended to be a record of all residents within a participating local authority area. However, the CA database is not as comprehensive as the pilot authority originally anticipated the total number of records provided by CA represented only 27% of the Renfrewshire electorate. The level of match between the CA data and the electoral register was high with 88.8% of the CA records also found on the register. The matching exercise suggested a small number of potential new electors (1.7% of the size of the register after local matching). Follow-up activity was still under way at time of publication. Pilot costs The overall cost of the pilots is estimated at around 425,910, against an original budget of 1.2m. These figures exclude staff costs for the Cabinet Office. The under-spend is largely explained by initial budgeting over-estimates by both Cabinet Office and the pilot authorities, due to a lack of clarity about what the pilot process would entail, and by many local authorities not completing some of the activities, e.g. follow-up work, which they originally planned for. Given the size of the over-estimates, it seems unlikely that the pilots would ever have cost the full amount budgeted. The main item of expenditure reported by local authorities is the costs of additional staff, which account for about 50% of the total spent by local authorities. Local authorities reported that the process was labour intensive 7

12 and they needed to incur much of this cost before they could begin the process of contacting potential new electors. Staff costs could be reduced by improving the quality of the data matched and automating more of the process but we cannot conclude, from the information gathered in these pilots, what the cost would be of any national data matching roll out. There was some limited expenditure on databases that were not used in the pilots and so did not deliver any benefit. While the costs of these pilots appear high in terms of numbers of people added to the registers this does not mean that data matching could not be cost effective if implemented differently. In order to assess potential scalability of data matching, it would be necessary to have more consistent information than is available about the costs incurred, and this information should include the additional internal costs incurred by both local authorities and data-holding organisations. Conclusions Our conclusions broadly follow the statutory evaluation criteria set out in Sections 35 and 36 of the Political Parties and Elections Act These criteria concern the degree to which data matching schemes assisted EROs in improving the completeness and accuracy of their registers; resulted in any issues around administration, time and costs; or prompted objections to the schemes. The registration objectives: completeness and accuracy On the whole, these pilots did not prove very effective at getting new electors on to the registers. Despite the efforts invested by authorities in the data pilots, very few additions (only 7,917) were subsequently made to the registers. However, better results were achieved where the local authority was able to begin their pilot follow-up activity before, or at a very early stage, of their annual canvass. This was largely because, where the follow up did not begin until later, many people had already registered through the canvass. In these pilots, the most useful databases in terms of adding people to the registers were those which targeted specific under-registered groups (e.g. 16-8

13 and 17-year-olds) such as the National Pupil Database (NPD) and the Individual Learner Record (ILR). The issues surrounding the currency of address information on some of the other databases would need to be addressed in order to improve their effectiveness at finding new electors. However, the low number of registrations does not mean that the principle of data matching is not worth pursuing further and many local authorities were clear that they still see potential in it. Refinements to the matching process such as improvements to the currency, quality and compatibility of the data provided would need to be in place before this objective could be fully tested. In relation to improving the accuracy of the registers, the MoD data was useful, up to a point, at helping EROs to amend or delete the records of service voters. Two local authorities amended or deleted a number of their records, representing 9.6% and 13.2% of the total number of service voters held on the register. However, there was limited testing of the usefulness of the other databases for improving accuracy with only one pilot providing information to the Commission on this aspect. Finally, not all the public national databases included in the current scheme were tested to the same degree. As set out earlier in the report, there was no testing of HEFCE or Royal Mail data by the pilot authorities and we are unable to draw any conclusions about the usefulness of this data in addressing the registration objectives. Objections to the schemes At the outset there were concerns that the use of public data in this way could generate objections from the public. However, where data has been provided, local authorities indicated they received few objections to the schemes. Where local authorities did receive queries, the vast majority of people were content with the use of the data when the purposes of the schemes were explained to them. This indicates that the data matching pilots did not generate any substantial level of concern amongst the public. However, any future testing or roll out of data matching would need to be well implemented in order to ensure there is continued public support. 9

14 Ease of administration Many pilots raised concerns that in its current format the process of data matching was too labour intensive for regular use. Additional staff resource was required by many of the authorities. In the main, this tended to be due to the large volumes of data received, issues with data compatibility and the workload involved in sorting the data for use. Many authorities also emphasised the need to understand the skill sets required for this kind of activity, and highlighted that in many cases these skills were not held by those currently working on registration activities. In the interim, developing the process of local data matching would not only be useful to EROs in maintaining the registers but would also help to build skills which could be used to understand and manipulate data provided from national databases. Time and costs The pilot schemes proved to be both time consuming and costly. However, it is not possible to draw robust conclusions about the long-term cost effectiveness of data matching from these pilots as the processes used here would not be repeated in a nationwide system of data matching. Nevertheless, it is clear that unless the process is made substantially more straightforward, it is doubtful that many authorities would have had the resources available to undertake data matching without additional finance which, in this case, was provided by the Cabinet Office. Recommendations This section sets out our recommendations for future data matching activities. Pilot processes Further testing of national databases by local authorities would need to be undertaken in order to establish whether data matching is made available for use by all local authorities. Any further testing needs to be set up in a way that addresses the limitations set out in this report in order to ensure that meaningful data can be collated. The Electoral Commission would encourage the Government to consult us in detail in order to achieve this. 10

15 We recommend that any further piloting (with a focus on improving accuracy and completeness): takes place outside of the annual canvass period and avoids other significant electoral events. Piloting data matching alongside the annual canvass added a layer of complexity to the testing process and meant it was harder for local authorities to isolate the impact of the data matching as opposed to canvass response rates. It also had consequences for local authority capacity to utilise the data when it was available to them. Several EROs thought that data matching could have more use following the canvass to pick up new registrants in the run-up to elections. has a clear framework for the use of data that all participating authorities can follow. This current scheme allowed local authorities to adopt varying approaches to piloting the data they received. The differing methodologies meant it was harder to draw conclusions about the effectiveness of the data and thus the future of the registration system. A clear framework would help to ensure comparability between the pilots but still allow for some local differences for example, targeting particular groups and making use of local databases. tests, as closely as possible, the process which would be made available to all local authorities if data matching was to be rolled out nationally. ensures that participating areas are sufficiently staffed and have appropriate expertise to complete the pilot and test the data provided. allows for a better understanding of the benefits of access to national data compared to existing local databases. allows for a clearer analysis of the cost of data matching through more informed budgeting and prescribed reporting of costs incurred. ensures that good communication between the pilots, the data holders and the Cabinet Office is maintained throughout the process. Databases In relation to the specific databases included in these schemes: 11

16 There is merit in re-testing nearly all of the databases included in these pilots providing the specific issues identified in this evaluation are addressed, namely that: address format compatibility issues should be mitigated where possible. The planned inclusion of Unique Property Reference Numbers (a unique identifier for each address held) on the DWP database will help with this issue, as will plans for a single national address file. Other mitigating steps could be taken for matches with other databases, for example using address cleansing software. Data currency issues should be tackled by ensuring that, where possible, the information shared includes details of the dates on which database records are updated. We would not recommend further testing of the MoD data, unless the range of data which can be shared is increased. While the data supplied in these schemes was useful for the pilot authorities it is likely to Proposals for verifying identity As outlined earlier, the Government is currently considering whether the results from the data matching exercise could be used to confirm the identity of individuals captured by the household canvass during the transition to IER. In relation to this, we recommend that: There is a need for more evidence to support this proposal, given that this is was not an objective of these pilots. Any future piloting that includes this as an objective for testing should allow for an analysis of matched and non-matched records in order to check the accuracy of the matching process used. It is possible that this analysis could use the annual canvass process. As a result the timing of these pilots may need to be slightly different to that of any pilots focused on accuracy and completeness. These plans should also stay abreast of developments in the. There are other initiatives within government on the processes that might be used in the future to verify identity. Learning lessons and adopting best practice from these other initiatives is important in order to ensure that the approach to verification followed under IER, and therefore the security of the registers, is as robust as possible. 12

17 1 Introduction 1.1 statutory evaluation of the 2011 data matching pilot schemes. The schemes were based on matching a range of national databases by Electoral Registration Officers (EROs) in 22 local authorities. This was the first time that EROs have been able to test the usefulness of national data for improving the quality of their electoral registers. 1.2 The overall aim of the pilot schemes was for EROs to test whether national public databases can help to improve the accuracy and completeness of their electoral registers. Background Accuracy and completeness of the electoral registers 1.3 Electoral registers underpin elections by providing the list of those who are eligible to vote. Those not included on the registers cannot take part in elections. Registers are also used for other important civic purposes, including selecting people to undertake jury service, and calculating electorates to inform Parliamentary and local government boundary reviews, which are the basis for ensuring representative democracy. People not registered are therefore not counted for these purposes either. 1.4 In addition, credit references agencies may purchase complete copies of electoral registers, which they use to confirm addresses supplied by applicants for bank accounts, credit cards, personal loans and mortgages. 1.5 Great Britain does not have one single electoral register. Rather, each local authority appoints an ERO who has responsibility for compiling an accurate and complete electoral register for their local area. 1.6 Accuracy The accuracy of the electoral registers is therefore a measure of the percentage of entries on the registers which relate to verified and eligible voters who are resident at that address. Inaccurate register entries may relate to entries which have become redundant (for example, due to people moving home), which are for people who are ineligible and have been included unintentionally, or which are fraudulent. 13

18 1.7 Completeness therefore refers to the percentage of eligible people who are registered at their current address. The proportion of eligible people who are not included on the register at their current address constitutes the rate of under-registration. 1.8 Great Br provided the first national estimates of the completeness of the electoral registers since estimates of the 2000 England and Wales registers, as well as the first national estimates of the accuracy of the registers since This study was funded by the Cabinet Office in order to inform the development of the approach to the introduction of individual electoral registration (IER). 1.9 The research estimated the April 2011 Parliamentary registers to be 82.3% complete; the comparable figure for the local government registers was 82.0%. This equates to approximately 8.5 million unregistered people in Great Britain as of April However, this does not mean that these registers should have had 8.5 million more entries, because many, but not all, of those not registered correctly may still have been represented on the registers by an inaccurate entry (for example, at a previous address) The April 2011 parliamentary registers were 85.5% accurate; the comparable figure for the local government registers was 85.4% The research also demonstrates the extent to which both the accuracy and completeness of the registers deteriorate between the publication of the registers in December each year and the time when elections are usually held in the following spring. Although in December 2010 the estimated number of people not registered in Great Britain was at least six million, by April 2011 the number had grown to around 8.5 million (17.7%). Current system of updating the electoral registers 1.12 At present, EROs use an annual canvass and rolling registration to update their registers. Individual electors can register to vote throughout the year by However, most updates to the registers take place during the annual canvass, which is undertaken each autumn. At its simplest, the canvass involves delivering a 6 data/assets/pdf_file/0007/145366/great-britainselectoral-registers-2011.pdf 14

19 registration form to each household and following up, via postal reminders and personal visits, those households who do not respond. Revised registers are then published on 1 December Almost all EROs use locally held data, such as council tax and housing records, to improve the effectiveness of their registration activity. However, EROs have not been able to make use of national databases in order to improve the quality of their local registers. Data matching and the move to individual electoral registration 1.14 The previous UK Government, during the passage of the Political Parties and Elections Act 2009 (PPE Act), introduced legislation providing for the phased introduction of individual electoral registration (IER) in Great Britain. The PPE Act made provision for IER to be introduced in accordance with a statutory timetable. The PPE Act also included provisions to allow data matching pilot schemes to be carried out, with a view to establishing which national public databases might be useful to EROs in helping maintain electoral registers during the transition to IER Under the PPE Act, data matching schemes approved by the Secretary of State would require a public or local authority to supply an ERO with data which they could then use for the purpose of maintaining complete and accurate registers In June 2011 the Coalition Government published a White Paper setting out its plans to speed up the implementation of IER in Great Britain. The new system to be implemented from 2014 will require each elector to register individually (unlike the current system where registration takes place predominantly by household) and to supply personal information for verification purposes prior to names being added to the electoral register The IER White Paper explained that the UK Government would explore, o identify people eligible to vote but missing from the register so they can invite 7 If successful the Government indicated that it would look at how data matching used in this way could be extended across the country and support the move to IER. 7 HM Government (2011) Individual Electoral Registration, Cm 8108, p11. 15

20 1.18 In February 2012 the UK Government published its response to prelegislative scrutiny and public consultation on the IER White Paper. 8 In the response, the UK Government indicated its intention subject to the results of the evaluation of pilot schemes and further testing to widen the scope of data The UK Government indicated that rather than only using data matching to identify potential electors, it was now their individuals currently on an electoral register will be matched against the data held by public bodies such as the DWP and local authorities themselves that I be matched, the individual will be automatically placed onto the new IER register and would not need to take any 9 Electors whose details could not be matched in this way would be asked to apply individually and to supply personal identifiers The UK Government has acknowledged that this would represent a significant change to the position set out in the White Paper, which envisaged all potential electors applying individually and supplying personal identifiers, with data matching used as a means of identifying potential electors. It stated its an efficient and effective system ready in time to support the implementation of 10 The Electoral Registration Data Schemes Order The Electoral Registration Data Schemes Order 2011 (the 2011 Order), made on 9 June 2011, gave effect to proposals by local authorities to run datamatching schemes. Under the 2011 Order, an agreement between the dataholding organisation and the ERO needed to be in place before personal data could be shared between the two parties. The purpose of the agreement was to explain governance arrangements for data transfer and matching, explain the expected outputs and inputs for this process, set out information security standards, and detail timescales The Cabinet Office was responsible for the selection and coordination of the schemes. The process for recruiting local authorities to run pilots was by 8 HM Government (2012) Government Response to pre-legislative scrutiny and public consultation on Individual Electoral Registration and amendments to Electoral Administration law, Cm Ibid. 10 Ibid. 16

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