Yes, absolutely. I think, in principle, we welcome automatic registration, because it removes a barrier to democratic participation. But as you rightly pointed out, there are significant risks around this, for instance, for survivors of domestic abuse, stalking or harassment, and these need to be managed very, very carefully.
I think, first of all, it's important to understand that they are real risks, even with the closed register. So, even when the open register is removed and we only have the closed register, there are still risks, even though that register can only be shared with a limited number of people in organisations. Given issues like police-perpetrated abuse, being on a closed register can pose a significant danger to survivors, if their personal information ends up in the wrong hands.
So, it's really crucial that people are able to register anonymously and there are provisions for this in the legislation, but we are concerned around the process. Partly, there's a concern that the 45 days are not long enough and this is because registering anonymously is not just a matter of self-disclosing, but survivors need to be able to provide evidence around this, and that can take a long time. They could be facing barriers to reporting; there could be delays to court proceedings, and all of this could delay their anonymous registration. And there would be additional challenges for survivors who are especially vulnerable, or for survivors whose first language isn't English or Welsh, who might struggle to understand and navigate that process.
And then there's also a problem, of course, of survivors having to go through all of this again at the next iteration. Some of these issues, we think, could be mitigated by extending the time frame beyond 45 days, by providing clear guidance and accessible formats in different languages, and by working very closely with specialist services who can support people in filing that request. But, I think, ideally, a really important thing to take action on would be on simplifying the process for registering anonymously, for instance, by allowing survivors to self-disclose and to change it so that once they're registered as anonymous, it will remain so until they actively opt out of anonymous registration. I think those are steps that could be taken to make the process safer. Uncertainty around people's personal data can always create a lot of anxiety and fear, and it might be helpful for people to have a straightforward way to check if they are registered anonymously.
There's an additional risk, of course, for people getting confused between devolved and non-devolved elections, so they might be unaware that they still need to opt out of the open register for non-devolved elections. So, that needs to be made very clear, otherwise people could inadvertently end up with having their personal data publicly accessible.