Other than that Regulatory Policy Committee (RPC) report on the Free Speech Bill (three weaks and a satisfactory), we were starting to think this year might be a bit thin on the trash front – but then a curio from the Cabinet Office appeared.
We often see “orphaned” research emerge from government departments. Sometimes it’s been commissioned at the behest of a minister that’s long since moved on, and sometimes it contains conclusions that would be embarrassing if noticed. This one – a report of some research carried out by IFF on behalf of the Cabinet Office on Student Electoral Registration – is a cracker.
During the passage of the Higher Education and Research Act, some friends in the Lords were keen to see automatic electoral registration reintroduced for students. Normally that would have been flicked off to other ministers, but a compromise was reached instead – the Office for Students was handed the task of creating, when registering a provider:
a condition requiring the governing body of the provider to take such steps as the OfS considers appropriate for facilitating cooperation between the provider and one or more electoral registration officers in England for the purpose of enabling the electoral registration of students who are on higher education courses provided by the provider.
It wasn’t possible to detect a whole lot of action in this area in the (too soon) 2017 election, but nor was it possible to detect much action in 2019 either (let alone in the run up to intervening locals) – and in the run up to that 2019 snap, universities minister and former Cabinet Office minister with responsibility for electoral registration Chris Skidmore’s only contribution was to amplify on Twitter the baseless culture wars allegation that students were being “registered against their will”.
I last looked at all of this in February 2020 just before the pandemic hit, in a piece in which I concluded that it was hard to find people that cared very much about the duty. What the Cabinet Office didn’t tell me at the time is that in August 2019 it had commissioned an evaluation of the condition which sought to understand how it was being interpreted and implemented within the sector, and its effectiveness to date. First the election and then pandemic got in the way – but now we have it.
It’s not what you’d describe as a “ringing endorsement”.
Methodologically, two surveys of provider staff at OfS-registered institutions ran in Autumn 2019 (158 responses) and were then repeated in Autumn 2020 (171 responses). A telephone survey of local authority electoral registration officers (EROs) took place in December 2020 (177 responses). Bizarrely, neither students nor their representative organisations were really in the research picture (a couple of focus groups were held at “case study” providers), which is especially frustrating given that it’s long been SUs that have driven the work in this space.
Perhaps tellingly, OfS barely seem to have been involved at all other than via a “depth interview”, and the explanation for the lack of focus given by OfS to IFF appears to be the old “well we’re risk based and we work off notifications”:
In line with OfS’ approach to regulation, their attention will be focussed on providers where issues have been raised that suggest a registered provider may not be meeting their requirements”
It’s an approach that I’ve critiqued before on the site, but on this IFF evidence OfS has a lot of providers on its hands that appear to not be meeting the requirements.
Bear in mind that this is an ongoing condition of registration with OfS. Only 81 per cent of providers had heard of the condition. 86 per cent of universities said they were “familiar” with it, falling to 30 per cent for FE colleges on the register and just 39 per cent of alternative providers.
Only two-fifths reported that they had actually read the OfS guidance outlining the requirements of the condition, and nearly half of all providers (47 per cent) reported that they had had no communications with any local authorities about it since its introduction!
Among Electoral Registration Officers (EROs), awareness levels were high – 90 per cent reported that they had heard of the condition, although only 29 per cent reported that they were familiar with its requirements.
IFF says that higher education providers and EROs generally had a positive, collaborative relationship, although there was some evidence of a “discrepancy of perspective”, with HE providers typically more positive about these partnerships. Well they would be, given the OfS duty is on them!
An expectation of the condition is cooperation between higher education providers and EROs to facilitate student electoral registration, which might include providers sharing student data with local authorities, EROs requesting evidence of providers conducting activities to facilitate student registration, and related work. Just over half of EROs reported experiencing some form of challenge when dealing with HE providers, and they said that only 71 per cent of HE providers had fully complied when asked.
EROs typically stated that a lack of compliance related to HE providers contending that the request was not GDPR compliant, and/or that they did not hold the information being sought.
And amazingly, only 20 per cent said they actually monitor student electoral registration numbers! Outcomes! Outcomes!
Disappointingly, only a quarter of HE providers (23 per cent) had embedded voter registration within student enrolment forms – but unsurprisingly, when asked which activities were considered to have had most impact on student registration, providers were more likely to point to this activity than any other. The efficacy of embedding voter registration in enrolment was echoed in qualitative findings where respondents described how it was a good opportunity to capture students while they were filling out other documentation such as for student loans and course enrolment.
There’s a funny little wrinkle in the IFF report, which seems to take at face value a widespread moan from EROs that even when built into enrolment, data supplied by universities wasn’t including NI numbers and so wasn’t usable. We worked out ages ago that proper work between EROs and universities would eliminate the need for students to quote their national insurance number. It’s hard to tell if the Cabinet Office has bothered to tell EROs – we’re not aware that OfS has told universities.
Ministers won’t be pulling any fingers out to improve student voter registration for obvious reasons. OfS definitely has some work to do here – people aren’t going to use “notifications” over a duty that they don’t know universities have, and I doubt that EROs will be using that system to moan about providers either. But again, you can’t see James “still a Tory peer” Wharton being super-thrilled at souping up work in this area.
Away from the condition – even if we ignored how important it is for students to be registered to vote morally and ethically, surely higher education providers of all types and stripes should have worked out by now how important it is that students are represented in the electoral maths of their area?
Come on folks. Before you go off on holiday, send that email – put the tick box into enrolment, schedule a meeting with EROs over the NI number issue, and let’s have this fixed once and for all in September.