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GLRO24-08 Materials for London boroughs’ polling stations and count centres, polling station training materials, tactile voting devices, ballot paper user testing and social media advertising

Key information

Decision type: GLRO

Directorate: Corporate Resources and Business Improvement

Reference code: GLRO24-08

Date signed:

Date published:

Decision by: Mary Harpley, Chief Officer of the GLA

Executive summary

This decision requests approval for expenditure:
•    to design, translate, print and deliver all statutory and non-statutory printed materials for: the 32 London boroughs, and the City of London, to use in their polling stations and in appropriate public spaces (e.g. information centres, council offices, libraries, etc); and for use at each of the count centres for the Mayor of London and London Assembly (“GLA”) elections in May 2024
•    to provide tactile voting devices to support blind and visually impaired voters casting their vote in polling stations across London
•    to develop polling station training materials, including online training, a PowerPoint template, and a video for the 32 London boroughs and the City of London
•    to user-test the five potential ballot papers for Constituency Assembly Member, London-wide Assembly Member (one and two-column versions), and Mayor of London (one and two-column versions)
•    to run social media public awareness advertising to inform voters of how, when and where to vote.
 

Decision

This decision requests approval for the following:
•    expenditure of up to £150,000 to procure and appoint a print management organisation to design and print statutory and non-statutory materials
•    the direct award of a contract valued at up to £100,000 to Pakflatt Ltd for Tactical Voting Devices and an attendant exemption from the Contracts and Funding Code on the grounds set out below
•    expenditure of up to £20,000 for polling station training
•    expenditure of up to £30,000 for qualitative testing of ballot papers
•    expenditure of up to £50,000 for social media advertising.
The total for this request is £350,000. These costs have been provided for as part of the overall Elections 2024 budget in 2023-24 and 2024-25. 
 

Part 1: Non-confidential facts and advice

Polling station and count centre materials
1.1.    The GLRO has a responsibility to provide all London boroughs with statutory and non-statutory voter information and polling station printed materials, as requested by them to use in the May 2024 elections for the Mayor of London and London Assembly (GLA elections). 
1.2.    On behalf of the GLRO, the GLA will procure a service provider for the design, translation, print and delivery of the printed materials to each of the 32 London boroughs, the City of London and City Hall, as per their requirements. To ensure timely delivery of the materials, the service provider will also be responsible for the overall project management of these activities and for implementing an accurate ordering system. 
1.3.    Statutory materials include: 
•    polling station notices (guidance to voters) (A2)
•    polling booth notices (guidance to voters) (A4)
•    laminated ballot poster (A3)
•    large-print ballot paper poster (A1).
1.4.    Non-statutory materials include: 
•    guidance to voters (multilingual)
•    statement of persons nominated (Assembly Member candidates) poster (A1)
•    Statement of persons nominated (list of Mayoral candidates) poster (A1)
•    City Hall count day booklet
•    voter information leaflet (DL 6pp)
•    voter information stands
•    catalogue of items (design only)
•    posters highlighting the change in Mayoral voting system.
1.5.    Multilingual versions are to be made available in the following languages:
•    Romanian 
•    Spanish
•    Polish
•    Bengali
•    Portuguese
•    Gujarati
•    Italian
•    Panjabi
•    Arabic
•    Tamil
•    Turkish
•    French
•    Urdu
•    Bulgarian
•    Persian/Farsi
•    Somali
•    Greek
•    Russian
•    Lithuanian
•    Albanian
•    Tagalog/Filipino
•    Hungarian
•    Nepalese
•    Hindi.
1.6.    Materials will be available as hard copies (printed versions that will be ordered from the supplier and delivered directly to the boroughs and City Hall) and as soft copies (PDF files) for use on the London Elects website and available on request to boroughs. 
1.7.    The print management organisation(s) will project-manage the process with oversight from the London Elects project team at the GLA, ensuring robust communication systems are in place from start to finish – including detailed project reporting as required.
Tactile voting devices
1.8.    Constituency Returning Officers (CROs) have a duty to make accessibility provisions for blind and partially sighted voters. By procuring tactile voting devices, we can ensure that a consistent minimum standard of provision is in place across Greater London; and that these voters can cast their votes without assistance. Approval is requested for expenditure to continue supplying the devices to boroughs.
1.9.    Section 10 of the GLA’s Contracts and Funding Code (the Code) provides that the GLA may directly award a contract without first running a competitive procurement where there is only one provider in the market, by reason of the provider’s exclusive intellectual property rights. Pakflatt Ltd is the only suitable supplier in the market to meet the GLA’s requirements, because it holds a patent in the design of tactile voting devices. As a result, Pakflatt Ltd was asked to quote for the design, manufacture, and supply of tactile voting devices for use with Constituency Assembly Member, London-wide Assembly Member and Mayoral ballot papers in the 2024 Elections.
1.10.    Due to Pakflatt Ltd’s exclusive intellectual property rights, no other supplier in the market could provide the devices without first obtaining a licence from Pakflatt Ltd. Even if Pakflatt Ltd were minded to grant such a licence, the likely licence fee would drive up the cost of the devices, beyond that which the GLA could achieve by going to Pakflatt Ltd directly. To that end, an exemption from the Code is sought as set out in the decision box above.
Polling station training
1.11.    The training offer to boroughs will include an interactive e-learning module, photos and instructional videos. It will be delivered by the Association of Electoral Administrators – the UK’s leading provider of electoral training – with a track record of delivery for GLA elections. It will include two versions: one for standalone GLA elections, and another for a UK general election combined poll.
1.12.    The training will be made available to all 32 London boroughs and the City of London. The audience will vary between boroughs but will be in the region of 400-500 staff per borough. Around 11,000 polling station staff are expected to take part in the online training.
1.13.    Boroughs will be free to create and complete any additional training they feel is appropriate. They can recover all training costs for the GLA elections from the GLA as part of their ‘maximum recoverable amount’ return. In the event of a combined poll, costs will be split with central government’s Election Claims Unit.
1.14.    The training video will be created by a freelance videographer with a track record of delivering work for TfL.
Ballot paper testing
1.15.    The 2021 elections saw high numbers of rejected ballot papers: 114,201, double the usual proportion. The abolition of the second preference vote in respect of the Mayoral election may reduce the risk of spoilt ballot papers, but it is still crucial that voters understand the ballot paper and its instructions – which will differ from 2021 in respect of the Mayoral ballot paper – and are able to complete it successfully. To help ensure this, we will be placing increased importance on messaging designed to explain how to vote as part of our public awareness campaign. Additionally, following recommendations from the London Assembly and the Electoral Commission as part of their 2021 election evaluations, the GLRO made a commitment to carry out testing of ballot papers ahead of the 2024 elections. It is noted that the precise design and format of the ballot papers is set out in the GLA Election Rules, with limited scope for the GLRO to make changes.
1.16.    The testing will be carried out by our contracted research agency, 2CV. The testing proposal includes structured interviews across four sessions with 18-20 participants per session. Participants will be sampled in order to ensure a range of age/life stage; socio-economic grade; gender; ethnicity; voting history (e.g. first-time voters, regular voters etc.); political affiliation (note: steps will be taken to ensure no group is over-represented, but no information on political affiliation will be included in the findings or seen by London Elects); and location (e.g. inner/outer, north/south London).
1.17.    The sessions will replicate the experience of voting as closely as possible, asking participants to complete the papers as they would in a real election. This approach is designed to ensure the findings are as ‘ecologically’ valid as possible. 
1.18.    Interviews will be conducted to establish whether respondents were able to cast their vote as they intended, and whether they found the ballot paper directions clear. By doing this we aim to establish whether voters find the experience of voting and following ballot paper instructions straightforward.
Social media advertising
1.19.    GLRO 24-02 approved expenditure of £450,000 for a public awareness campaign ahead of the 2024 elections. The main purpose of this is to meet the GLRO’s statutory responsibility to inform the London electorate that elections are taking place on 2 May 2024, and that they can visit LondonElects.org.uk for more information. This sum was arrived at in consultation with the GLA’s contracted media buying and planning agency, Wavemaker, to establish the budget level that would ensure the same or a greater level of reach than achieved in 2021. The channel mix for this campaign is likely to include out-of-home advertising; radio and digital audio; and digital display. However, in a departure from previous years, it will not include social media advertising.
1.20.    In keeping with the wider approach to marketing campaigns at the GLA, we plan to buy social media through our in-house Digital Communications team directly from media owners, rather than via an external agency. The primary focus of this activity will be on promoting secondary messages, in particular how to complete the three ballot papers used in the election. By running the advertising in-house we can avoid agency fees, leading to greater reach for our budget; and ensure greater flexibility, meaning we can promote or prioritise messages at short notice.
1.21.    This is particularly important for promoting our secondary messages (such as how to complete the ballot papers) which we cannot include in broadcast formats such as out-of-home or radio advertising. It is also important in the event of a combined poll, where we may wish to change or reprioritise messages at short notice. A budget of up to £50,000 has been discussed with the GLRO and is proposed to be allocated to in-house social media advertising. 
1.22.    The channels used will be determined in discussion with our in-house digital communications strategists; and will be selected in order to reach a pan-London audience of voters in an untargeted way, in line with our wider campaign approach. Channels used are likely to include Facebook and Instagram, which will be bought directly on-platform in line with the wider GLA approach. 
 

Polling station materials
2.1.    To support London boroughs and provide them with statutory and non-statutory printed materials (including multilingual materials) they require for the polling stations and to inform voters.
2.2.    Deliver the quantities and/or files of the individual materials requested as per the requirements of 32 London boroughs and City of London. 
Tactile voting devices
2.3.    To ensure high standards of accessibility for blind and visually impaired voters are maintained across London.
Polling station training
2.4.    To provide an online training system for all borough polling station staff that will ensure a consistent high level of training across London, while allowing boroughs to tailor their training offer as needed.
2.5.    To allow for the face-to-face experience for the elector to be the same regardless of where they are voting in London, in particular relating to voter ID checks.
2.6.    To ensure that the key message to voters on the voting systems, the number of ballot papers and the number of votes each elector has is clearly communicated.
Ballot paper testing
2.7.    Ensure ballot papers are easy to understand and use, and that people are able to complete them accurately.
2.8.    Explore reactions and responses to the ballot papers, to identify any areas requiring optimisation.
2.9.    Ensure that this paper works equally well for all Londoners. 
Social media advertising
2.10.    Run social media advertising designed to inform voters of how, when and where to vote. This will be run by our in-house Digital Communications team, buying directly from social media owners rather than via an external agency.
 

Key risks and issues
3.1.    CROs have a statutory duty to provide these materials to their electorate. Adherence to strict timelines is compulsory. Failure to do so would be a breach of legislation. 
3.2.    CROs have a statutory duty to make available tactile voting devices at polling stations to those voters that need such assistance.
3.3.    We are contingency planning for a possible UK general election in May 2024, and will create versions of the training for a combined poll.
3.4.    We will also contingency plan for changes in messaging and prioritisation on social media in the event of a combined poll.
3.5.    We will treat the Mayoral and Assembly elections equally in our messaging, in keeping with our wider campaign approach.
Impact assessments and consultations
3.6.    Soft market testing has been carried out with the GLA’s incumbent print management company to help determine increases in prices and inform budget calculations for 2024. Costs have been estimated based on a cost estimate supplied by our supplier, CDS, with some contingency factored in. 
3.7.    In 2021 we implemented a delivery portal allowing boroughs to order assets online from a single supplier. This was widely approved of by borough colleagues as an efficient process for monitoring and reporting, and we plan to replicate this approach in 2024. 
3.8.    We will seek feedback from boroughs on the utility of our approach to training following the elections, in order to inform our approach for 2028.
3.9.    We will evaluate our social media advertising by setting performance targets, specifically reach/views and, where appropriate, traffic to the London Elects website. 
 

4.1.    Under section 149 of the Equality Act 2010 (the Equality Act), public authorities must have due regard to the need to eliminate discrimination, harassment and victimisation, and any conduct that is prohibited by or under the Equality Act; and to advance equality of opportunity, and foster good relations, between people who share a protected characteristic and those who do not. In the context of the 2024 elections this means that: in making the arrangements for members of the public to vote, any specific needs of people with protected characteristics must be properly taken into account; and they are not put at a disadvantage compared with other members of the public exercising their right to vote. 
4.2.    The London boroughs and the City of London will follow the Electoral Commission guidance about accessibility awareness. Equipment at the polling station will be provided to support equal access to voting for all. As in previous years, London Elects will support the boroughs in ensuring equality requirements are fully met. 
4.3.    Large-print and translated versions of specific materials will be available to order as required by individual boroughs. 
4.4.    All materials designed and printed will adhere to the Royal National Institute of Blind People’s See It Right legibility standards.
4.5.    All digital formats will be in line with the GLA’s Digital Accessibility Policy
4.6.    As noted above, materials will be made available in a range of languages. 

5.1.    This Decision approves:
•    expenditure of up to £150,000 to procure and appoint a print management organisation(s) to:
o    design and print the statutory and non-statutory materials required by the London boroughs
o    implement a robust and effective ordering system by which the boroughs can state their requirements and have these materials delivered directly to them; this includes voter information and polling station materials
o    manage the accurate translation of multilingual materials to ensure complete accuracy and consistency across materials, including large-print versions
•    the procurement valued at up to £100,000 of PakFlatt (UK) Ltd for:
o    the supply of tactile voting devices for use at polling stations to enable blind or partially sighted electors to vote independently and in private: the requirement is for up to 4,000 sets of three tactile voting devices, namely one for each of the three ballot papers (Mayor of London, London-wide Assembly Member and Constituency Assembly Member)
o    a related exemption from the requirements of section 10 of the GLA’s Contracts and Funding Code, given that there is no competition in the marketplace for tactile voting devices; their provision is recommended to ensure a consistent minimum standard of provision for blind and partially sighted voters across London to cast their votes without assistance
•    expenditure of up to £20,000 for:
o    polling station training including interactive online training, photos, a PowerPoint template and an instructional video for up to 32 borough councils and the City of London; It will be delivered by the Association of Electoral Administrators, the UK’s leading provider of electoral training, with a track record of delivery for GLA elections
o    training will be customisable according to local need, but will ensure a minimum standard across London
•    expenditure of up to £30,000 for:
o    qualitative testing of the five ballot papers with the London electorate (including one- and two-column versions of Mayor of London and London-wide Assembly Member ballot papers) 
o    testing to take place at four locations, with a representative group of 18-20 eligible Londoners per location
o    testing to be carried out by research agency 2CV, which is contracted to the GLA and has recently carried out elections creative development research
•    expenditure of up to £50,000 for:
o    social media advertising to be bought directly from social media companies, for the purpose of raising awareness of how, when and where to vote
o    budget to be used on social media platforms directly: precise channels and formats, yet to be determined, will be those that will ensure the best, most balanced reach among Londoners; this is likely to include Facebook and Instagram.
 

6.1.    The proposed expenditure for which approval is sought is consistent with the GLRO’s statutory powers and duties.
6.2.    The procurement of the tactile voting devices from Pakflatt Ltd is valued at up to £100,000. Section 9 of the GLA’s Contracts and Funding Code requires that the GLA undertake a formal tender process or make a call-off from an accessible framework for procurements with a value between £10,000 and £150,000. However, section 10 of the Code also provides that an exemption from this requirement may be justified on the basis of exclusive intellectual property rights. Officers have set out at paragraphs 1.8 to 1.10, above, the reasons the procurement of devices from Pakflatt Ltd falls within the said exemption. Accordingly, the GLRO may approve the exemption, if she is so minded.
6.3.    The other decisions above seek approval for the procurement of various services including training, testing of ballot papers and social media advertising. Officers are reminded to comply with the Code when they procure the various services and to put in place an appropriate agreement between the GLA and the relevant service provider before the services commence.
 

7.1.    The project will be delivered according to the timeline set out below: 

Activity

Timeline

Procurement of polling station materials contract

January-August 2023

Training video filming

October 2023

Ballot paper research fieldwork

January 2024

Final training delivered

January 2024

Delivery start date

February 2024

Social media advertising to run

March-May 2024

Delivery end date

May 2024

Final evaluation start and finish

May-July 2024

Project closure

July 2024

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