Individual Electoral Registration Draft Legislation (Cabinet Office)

October 2011

Response from Royal National Institute of Blind People (RNIB)

1. Introduction

We welcome the opportunity to respond to this consultation. We broadly support the aims of the Government. Together with Scope and many other organisations working with disabled people, we hope a move to individual voter registration can tackle key barriers to voting.

Our key concern is to make sure changes to registration meet the specific needs of blind and partially sighted people. That means ensuring the transformation programme takes full account of blind and partially sighted people’s needs, both in terms of publicising and explaining the changes, but also enabling individuals to register with the minimum level of complication.

2. Key principles

The Royal National Institute of Blind People believes the transformation programme needs to be rooted in the following principles:

Accessibility: Clearly individual voter registration must be accessible to people with a visual impairment. This could be achieved by providing a freepost pullout, which enables a visually impaired individual to return their details, including their preferred reading format. Until electoral administrators ascertain that an individual needs information in a format other than standard print, the voter registration system will exclude blind and partially sighted people. Recording an individual’s access needs at the time of registration will instil confidence in the system. It means that from registration through to polling day, electoral administrators have the information they need to make reasonable adjustments.

Whatever changes take place in terms of canvassing, RNIB would like assurances electoral administrators will take proactive steps to identify individuals’ access needs, including their preferred reading format.

Autonomy: Research conducted for RNIB by Dr Foster (2009) suggests that around 25 per cent of blind and partially sighted people do not have anyone to read to them. The main explanation for this is the greater likelihood that people living with sight loss will be of pensionable age, and may therefore be widowed or live on their own. The current paper-based system is based on unfair assumptions that blind and partially sighted people can find out about voting from family and friends.

The transformation programme must recognise the additional barriers posed to registering where a disabled individual lives on their own. In the case of blind and partially sighted people, the system must be designed in such a way that individuals can register without having to rely on strangers or acquaintances. Again, a large print pullout insert which enables someone to record his or her preferred reading format would represent a useful stepping stone.

Co-design: We are pleased theCabinet Office has taken measures to consult and involve organisations of disabled people. We would like to see disabled people actively involved in co-designing the new registration system all the way through to implementation in 2014. Disabled people are the best placed people to comment on the design of the registration form. Blind and partially sighted people experienced difficulties with completing the Census 2011, so there are lessons to learn here. They have a huge wealth of expertise to share; so for example a proper process of co-design would have prevented the situation that meant the unique identifier on print forms of the Census included an inaccessible alpha numeric code. That was problematic because even where individuals were encouraged to fill in the form online (as an alternative to relying on standard print), they still needed the inaccessible print code.

RNIB would be happy to work with the Cabinet Office on the technical aspects of a new registration system. Even where individuals cannot sign their name as proof of identity, we are increasingly seeing straightforward, secure means of proving user identification. For example the Cabinet Office may wish to look at the example set by PayPal who authorise individual transactions through a new “ring back” system. Where disabled individuals cannot access encrypted codes they offer an alternative channel for authorising payment, through a unique identifier code delivered on the telephone. The onus is on the individual to key in that secure code to complete the transaction. We would be willing to explore the applicability of such a system to individual voter registration.

Flexibility: We welcome steps to modernise the electoral registration system through the introduction of electronic ways of registering. The electoral registration form must not be prescribed in statute. We credit the Government with recognising the importance of getting accessibility right from the outset. We were pleased to learn that individuals will not be required to provide a signature on the registration form. To properly tailor the information individuals receive nearer to polling date, we recommend there is enough in-built flexibility to capture voters’ accessibility needs at the time of registration. This of course means providing multi channel approaches to registering, including electronically, but it also means assisting individuals where there is an obvious case for exempting them from providing common personal identifiers.

Government must ensure that the mechanism for completing the registration form electronically is made as simple as possible and consideration is taken of disabled people’s needs when designing the entire process. Careful consideration should be given to providing a clear set of alternative identifiers where disabled people cannot provide a National Insurance number. This is particularly important for disabled adults in residential settings.

Integration: If access needs are collected at the point of registration, we cannot see any obvious impediment to making sure this information is used in the run-up to polling day and on polling day itself. Electoral registration officers should have all the information they need to subsequently provide polling cards and other materials in the format a visually impaired person has specified. Equally we cannot see any obvious reason why someone’s access needs won’t be shared with a Returning Officer, so we urge complete integration between all the relevant parts of electoral services. If a blind person requires a tactile voting device or a partially sighted person needs a ballot paper in large print, it should be obvious whom will need this and how many copies need to be provided at any one polling station. Again, the key point is obtaining an individual’s access needs at the point of registration.

We would also like to work with the Cabinet Office to explore the scope for using the information contained on local authority registers. We would like the Government to consider the feasibility of sharing personal information contained on local authority registers of blind and partially sighted people (this is information that has already been consented to). In this way, adult social care teams could share information with electoral services so they know whom to approach with accessible registration forms. Capturing a blind or partially sighted person’s access needs at registration stage has the potential to transform visually impaired residents’ experience of local authority services, so if there are any other ways of sharing people’s accessibility needs, we would like the Government to give that urgent attention.

3. Conclusion

We agree with the principles underpinning the electoral transformation programme. Although we have specific concerns around accessibility and flexibility we remain optimistic individual voter registration will tackle systemic barriers to information, not just in terms of voting but potentially across a wide range of local authority-provided services. The transition process must be handled carefully, so for instance disabled voters who rely on postal votes and voting by proxy should be given information on the changes that will affect them well in advance. Notwithstanding this, we remain prepared to work with the Cabinet Office to consider the technical aspects of rolling out individual voter registration to blind and partially sighted people and look forward to a process of co-design.

For more information on this submission please contact

Andrew Kaye (Policy Manager) or Hugh Huddy (Campaigns Officer, Inclusive Society)

Royal National Institute of Blind People

020 7391 2123

About RNIB

As the largest organisation of blind and partially sighted people in the UK, RNIB is pleased to have the opportunity to respond to this consultation.

We are a membership organisation with over 10,000 members who are blind, partially sighted or the friends and family of people with sight loss. 80 per cent of our Trustees and Assembly Members are blind or partially sighted. We encourage members to be involved in our work and regularly consult with them on government policy and their ideas for change.

As a campaigning organisation of blind and partially sighted people, we fight for the rights of people with sight loss in each of the UK’s countries.

During the next five years we want to tackle the isolation of sight loss by focusing on three clear priorities:

Stopping people losing their sight unnecessarily;
Supporting blind and partially sighted people to live independent lives; and
Creating a society that is inclusive of blind and partially sighted people.

We also provide expert knowledge to business and the public sector through consultancy on improving the accessibility of the built environment, technology, products and services.