Nick Martin discusses the UK Electoral Roll and how changes to it will affect marketers. 

My eldest daughter attained the age of majority last month and duly received an application to be included in the register of electors.

I clearly need to learn to let her stand on her own two feet, but I sat down with her to complete it, ensuring that her vote counts in the impending May 6 UK General Election. It seemed only yesterday that I completed my own details for the first time; a short 30 years ago!

While the approach of electoral services to form design varies across local governments, this one set down a clear 

opt-out from the Edited Electoral Register (EER) and explicitly highlighted that ‘this list can be used for marketing’.

For the benefit of non-UK readers, the EER is used as a substantial part of any consumer marketing base file, as well as for validation and household residency decisions.

While the size of the file has reduced with increasing opt-outs and the effect of some councils pre-ticking an opt-out from other uses, it still stands at 24.8 million consumers: a substantial proportion of most consumer universe files.

My impression as a consumer was very different from the key underlying premise of the Data Sharing Review produced by Dr Mark Walport and Richard Thomas in respect of its recommendation to abolish the EER: ". . . selling the edited register is an unsatisfactory way for local authorities to treat personal information. It sends a particularly poor message to the public that personal information collected for something as vital as participation in the democratic process can be sold to ‘anyone for any purpose’.  And there is a belief that the sale of the electoral register deters some people from registering at all."

As a result, the Ministry of Justice opened consultation to invite views and evidence from the public and other stakeholders about how they could be affected by its abolition and proposed six options:

Option 1: Abolish the EER as soon as practicable. 

Option 2: Set a timescale or ‘trigger point’ for abolition of the EER. 

Option 3: Abolish the EER as soon as practicable, but extend access to the Full Register for other purposes to be decided in light of the consultation. 

Option 4: Retain the EER, but impose restrictions in legislation on who can purchase it and for what purposes. 

Option 5: Replace the current ‘opt out’ provision with ‘opt in’. 

Option 6: Improve guidance for the public about the EER.

Round table

A round table was convened recently to bring together stakeholders; the DMA, business practitioners, service providers, privacy officers and lawyers.

A strong consensus had been built around the third option, to abolish the EER but to extend use of the whole Electoral Roll of 46 million consumers for validation of household composition.

This would solve the inevitably growing problem of poor addressing, ensure accuracy of targeting and protection of minors from mistaken inclusion in campaigns – principally, but not exclusively, in relation to cold acquisition marketing.

An arms-length body that would licence and oversee through a tough auditing regime would make sense to allay concerns over abuse; a very interesting idea. 

Compelling proposal

As a result of the discussion, a compelling proposal was also put forward to support the forth option – to retain the EER but to impose tighter restrictions upon its use and by whom. 

As we know, consumer information is used to build aggregated views of population by small units of geography and this is then used for all kinds of decision support; from retail shopping centre and store planning to a huge range of analysis by governmental organisations, such as where to pinpoint inward investment, spend seed money on new business parks and office space and prioritise rural access.

Aggregated data depends on accurate inputs at the most granular level possible, otherwise inaccuracies are magnified and the base subsequently used for business and government/ public service planning drives erroneous decisions. 

This should be avoided at all costs, and therefore retaining the EER for these purposes is highly desirable for all the stakeholders, on every side of the argument with an interest in the Ministry of Justice’s consultation.

I hope the Government decides on the clear value of accurate information for certain defined purposes.

With two months to go before my daughter casts her vote for the very first time along with the rest of us, it may well prove a very big ask.

Nick Martin is a regular columnist for DMI. Email him: martin.nick@btinternet.com

Read his blog here: marketingpages.typepad.com/marketingpages