Use of the electoral register

At a glance

• Registered political parties, candidates and campaigners are entitled to receive copies of the full electoral register which includes eligible voters’ names and addresses.
• They are also entitled to access the “marked register”, which enables identification of individuals who have voted in previous elections and referendums, but not how they have voted.
• Access to this information is important for promoting political participation. Its use can be compatible with data protection law, which must still be complied with.

In more detail

• What is the electoral register?
• Can we use personal data from the electoral register for our political campaigning?
• Can we use the electoral register to check if donations are from permitted sources?

What is the electoral register?

People eligible to vote in UK elections and referenda are required to register to vote. Their names and addresses are held on the electoral register. There are two versions of this register - the full register and the open register (called the "edited register" in Northern Ireland).

The open register is available for anybody to purchase. Individuals have the right to opt out of appearing on the open register. The full version has restricted access and there is no right to opt out.

Can we use personal data from the electoral register for political campaigning purposes?

Registered political parties, candidates, registered referendum campaigners, registered non-party campaigners (who campaign at elections) and registered recall petition campaigners are entitled to receive copies of the full electoral register, under the Representation of the People Regulations 2001. They are also entitled to access the “marked register’”(where they reach certain criteria), which enables identification of individuals who have voted in previous elections and referendums, but not how they have voted.

Much political campaigning makes use of the names and addresses held on the electoral register. Access to this information is important. It helps you to convey your messages to voters - furthering political debate and promoting democratic participation. However, even if you have the legal right to process the information contained within the full electoral register, it is important to understand that this does not exempt you from complying with data protection law.

In particular, you must:

• only obtain and use the register in ways compatible with electoral law;
• take steps to ensure the accuracy of the data. You should request updated versions of the register on a regular basis. Using older versions risks writing to people who are no longer living in certain addresses or not taking account of other factors such as changes of name or individual wishes not to be on the register;
• not share electoral register data with any other controllers; and
• only share data with processors where allowed under electoral law.

In addition, even though there is a legal entitlement to obtain and process electoral register data, you must still meet the requirement in UK GDPR to provide privacy information to those individuals. As a controller you must take all reasonable steps to do this, which could include signposting to other sources of information about how the register is used.

The ICO does not expect this to extend to campaigners contacting all voters directly with this information, but you must take regular and active steps to communicate alongside other privacy information. We also expect relevant controllers to take part in any centralised transparency initiatives organised by the ICO or the Electoral Commission.

Can we use the electoral register to check if donations are from permitted sources?

Campaigners raise funds to run their election campaigns. There are rules about donations or loans given to candidates, political parties and registered non-party campaigners in the UK. These rules mean that you have to check if donations are from permitted sources. This often involves checking whether an individual donor is on a UK electoral register. Checking personal data against the electoral register for this purpose is permissible under data protection law. However, you must ensure that you process this register data in accordance with the data protection principles.