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Can marketers live without the Edited Electoral Register?

The biggest electoral change in 80 years is about to take place, one that could have aprofound effect on the Edited Electoral Register (EER), a valuable source of data for the marketing industry for over 30 years. Individual Electoral Registration (IER) will replace the current annual household canvass in 2014. As we wait for the new rules to be introduced, it is timely to look again at the threats to the use of electoral registration data for marketing and whether ER data is even relevant to direct marketing anymore.

Timetable of changes to Electoral Register
The Electoral Registration and Administration Act became law in January 2013, allowing for the introduction of IER from 2014. There will be one last annual household canvass in advance of the introduction of IER in early 2014, with the final household Registers published on 17 February 2014.

These Registers will then be matched to the Department of Work and Pensions Customer Information System (DWP CIS) – basically the information the government holds on citizens via the tax and benefit system – during the summer of 2014 (a process called “confirmation”). Those names and addresses that match to the DWP CIS will be transferred to the new individual Registers.

In 2012, a pilot exercise covering 14 local authorities achieved a creditable average match rate of just over 70%. There will also be a dry run this summer where all local authority registers will be matched.

Electoral registration officers for each area will then be left to try and validate the remaining names by a further process of matching to local databases and by trying to contact those individuals and asking them to register as individuals using their national insurance numbers and other data as identity checks.

Impact on marketing and Edited Electoral Register
So what does all this mean for the EER and direct marketing? Firstly, there will be an edited version of the new individual register that can be used for marketing. The Coalition Government does not appear to have accepted the Walport recommendation to abolish the EER as part of the process of moving to individual registration.

Secondly, it seems that the opt-outs recorded on the last household canvass will be transferred to the new individual registers. So if everyone captured on the last household canvass was “confirmed” or individually registered on the new register, the size and shape of the new individual EER would not change very much from the last household version.

However, there is some concern that the move to individual registration could result in a fall in total registrations, particularly among those groups already under-represented on the current Register (the young, the poor and some ethnic minorities). The Electoral Commission thinks this fall could be considerable (as much as 30% or about 15 million individuals) and this could impact on the first individual EER.

How relevant to marketers is the Edited Electoral Register?
Does any of this matter? Isn’t the size of the EER diminishing anyway as more and more people opt out? And shouldn’t direct marketers be using other data sources anyway instead of relying on a voter database?

Certainly, the number of people opting out of the EER rose rapidly in the first few years. The national opt-out rate peaked in 2010 at 46% but has fallen in each of the last two years to 40% in 2012. That is despite many electoral registration officers trying to increase the opt out-rates by pre-ticking the opt-out box based on previously expressed preferences (technically illegal) and by encouraging consumers to use Section 11 notices under the Data Protection Act to permanently opt out of receiving unsolicited marketing communications.

So the size of the current EER, with a 40% opt-out rate, is around 28 million individuals, all validated at their current address in the last 12 months. No other commercially available database of names and addresses comes close to this. No wonder that the EER is still a hugely valuable data source for direct marketing, whether as an accurate source of names and addresses for prospect mailings and prospect databases or as a validation resource for names and addresses from other sources, including an advertiser’s own customer database. Many of the UK’s biggest brands use data from the EER, including EDF Energy, Legal and General, Virgin Media and Lloyds Banking Group.

Of course the names and addresses on the EER, when used for direct marketing, are selected using a wide range of targeting variables derived from geodemographic, lifestyle and transactional sources. These variables are what drive the communication; the EER provides the accuracy of the name and address.

Could we live without the Edited Electoral Register?
If we had to, obviously we could. The direct marketing industry is nothing if not adaptable. Data costs would almost certainly increase and data accuracy would fall. New data sources would undoubtedly be created, but we all know how difficult and expensive it is to create large opted-in files of consumer names and addresses.

Despite the growth of digital channels and email, direct mail is an essential part of the marketing mix, playing a vital role in the customer journey. And direct mail relies on accurate opted-in names and addresses. So, while the EER is still available, we should recognise its value and, given the right of consumers to opt out, continue to defend our right to use it.

Paul Winters, Managing Director, Marketing Solutions Division, CACI Ltd

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