The Ministry of Justice (MoJ) will
shortly be consulting with interested parties on the future
availability of the edited electoral register. This register, from
which voters have the right to opt out (although relatively few do
so), is presently available for commercial uses such as tracing
debtors.
Ministers announced this review following a
legislative challenge to the continuation of the edited register in
the House of Lords.
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Some peers (mainly in opposition parties) proposed
its abolition in an amendment to the Political Parties and
Elections Bill currently proceeding through parliament. This
amendment was withdrawn, following the promise of the coming
consultations.
Use of the full unedited voters’ lists for
commercial electronic searches is confined to credit reference
checks and compliance with money laundering regulations. This seems
unlikely to change.
The permitted credit reference use of the full list
is defined as “vetting applications for credit or applications that
can result in the giving of credit”. This is contained in
Regulation 114 in the Representation of the People (England and
Wales) (Amendment) Regulations 2002.
The wording is similar in the corresponding
enactments for Scotland and Northern Ireland.
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By GlobalDataOn some interpretations, credit checks prior to
increasing or reducing borrowing limits under existing facilities
require use of the edited register. However, such variations will
not often arise in point-of-sale motor finance.
Due to the opt-out facility, the edited register
may be of limited use in managing fraud losses. The credit industry
nevertheless makes extensive use of it for general tracing and
collection work. There is therefore some concern at the forthcoming
MoJ review.
One possible outcome would be prohibit use of the
edited register for marketing purposes (i.e. unsolicited mail
shots), but to leave it in place for all other uses.
This would have little impact on the credit
industry, and practically none on point-of-sale finance. Yet the
complete abolition of the edited register has not been ruled
out.
Ed Simpson, head of government affairs at the
Finance & Leasing Association, said: “We lobbied hard against
the Lords’ amendment so welcomed its withdrawal.
“We await the formal consultation, and we shall be
concerned to ensure that it does not threaten responsible lending
and credit management.”
