The UK is subject to Europe-wide rules due to various treaties and agreements associated with its membership of the European Community. The Act does not apply to elections to the European Parliament. Following "Hirst v United Kingdom (No 2)" (2005), in which the European Court of Human Rights (ECHR) ruled such a ban to be disproportionate, the policy was reviewed by the UK government. In 2005 the Secretary of State for Constitutional Affairs, Lord Falconer of Thoroton, stated that the review may result in the UK allowing some prisoners to vote. In 2010 the UK was still reviewing the policy, following an "unprecedented warning" from the Council of Europe. The UK government position was then that: