Full Electoral Register

I refer to your request under the Freedom of Information Act regarding the Full Electoral Register. The registration of electors is governed by the Representation of the People Act 1983 as amended. Under Section 8 of the Act, the council must appoint an officer of the council to be the registration officer for any constituency or part of a constituency coterminous with or situated in the council’s area. I am the appointed officer for the registration area of Brighton & Hove City Council. My appointment as Electoral Registration Officer is separate to my appointment as Chief Executive and, although appointed by the council, the Electoral Registration Officer’s responsibilities and duties are personal. An example of this is that the register of electors is deemed to be the property of the Electoral Registration Officer, not the local authority.

The Electoral Registration Officer does not carry out the duties on behalf of the local authority but in his own personal capacity. A list of public bodies and local authorities that are subject to the provisions of the Freedom of Information Act is available at the following website:

https://www.gov.uk/make-a-freedom-of-inf...

As you will see, the Freedom of Information Act does not list any person appointed under the Representation of the People Act 1983. It follows that the Electoral Registration Officer, Returning Officer or any other person appointed under the Act are not subject to the provisions of the Freedom of Information Act.

Notwithstanding that there is no statutory obligation to provide this information, the answers to your questions are as follows:

“Other than normal “public inspection” of the paper version of the Full Electoral Register under the supervision of the Electoral Registration staff (or electronic access to the Edited Electoral Register):

1. Does the council maintain a list of employees that have access to the Full Electoral Register? Yes we do. They are the Electoral Services Team – Claire Wardle, Charlotte L’Esperance, David James, Patricia Crunden, Erica Keating, Tracey Barsley, Dave Jones, Will Skyrme and Adam Fishwick who produce the register. I have also attached a list of the five people from other departments that have access to either a paper copy or data copy of the Full Electoral Register.

2. Approximately how many council staff have access to the Full Register? 9 from the Electoral Services team and 5 from other council departments = 14

3. Are employees that have access to the Full Electoral Register required to sign any written undertakings in relation to the
employees' use of the Full Electoral Register? The Electoral Services team are bound by the clause in their contracts regarding “Confidentiality and Data Protection”. The 5 people from other council departments have to sign the attached order form/declaration which sets out their entitlement to the Electoral Register as a council employee .

If so please enclose a copy of the draft undertakings. (see attached for undertakings)

4. Are logs maintained of each search of the Full Electoral Register that is made by each employee? No logs are made of each search made by employees

5. In the last 12 months have any audits been made to check that searches made by employees of the Full Electoral Register
were made in accordance with the relevant regulations? No audits have been made in the last twelve months in relation to the
searches made by these employees.

6. For what purposes is the Full Electoral Register used by the council? The Full Electoral Register is used for security, law enforcement, crime prevention and for statistical purposes. I do not hold detailed information regarding these searches.

For each purpose below please mark either Y(Yes) or N(No) in the second column, to indicate whether the Full Electoral Register is used by the council in that way.
Checking applications to rent council property N
Tracing residents for littering offences N
Checking whether a person lives in a certain borough to assess eligibility for services N
Resolving returned mail Y
Sending residents non-political information leaflets and mail such as council newsletters N
Tracing people to collect council tax Y
Checking single person occupancy Y
Assessing other benefit entitlements N
Tracing people to collect business rates debts Y
Tracing people in relation to housing benefit over-payment N
Checking residency for parking permit applications N
Tracing people who owe parking fines N
Tracing people who owe other debts N
Legal disputes N
Checking residency of trading standards complainants N
Tracing traders suspected of a crime N

Any other purposes (please list below):”
Checking occupants of property in order to serve Tree Preservation Order documents
Checking occupancy in connection with investigating offences and possible offences under Housing Act and other environmental health-based legislation relating to residential properties.
Checking names of occupants for investigations into possible offences relating to the Environmental Protection Act 1990, Control of Pests Act, and other possible environmental offences.

If you have any further queries regarding this matter please contact the Electoral Services Manager, Charlotte L’Esperance on 01273 294120 or email charlotte.l’esperance@brighton-hove.gcsx.gov.uk

Yours faithfully

Penelope Thompson
Electoral Registration Officer