Elections
Federal Efforts to Improve Security and Reliability of Electronic Voting Systems Are Under Way, but Key Activities Need to Be Completed Gao ID: GAO-05-956 September 21, 2005The Help America Vote Act of 2002 established the Election Assistance Commission (EAC) to help improve state and local administration of federal elections and authorized funding for state and local governments to expand their use of electronic voting systems. EAC began operations in January 2004. However, reported problems with electronic voting systems have led to questions about the security and reliability of these systems. GAO was requested to (1) determine the significant security and reliability concerns identified about electronic voting systems, (2) identify recommended practices relevant to ensuring the security and reliability of these systems, and (3) describe actions taken or planned to improve their security and reliability.
While electronic voting systems hold promise for improving the election process, numerous entities have raised concerns about their security and reliability, citing instances of weak security controls, system design flaws, inadequate system version control, inadequate security testing, incorrect system configuration, poor security management, and vague or incomplete voting system standards. It is important to note that many of these concerns were based on specific system makes and models or a specific jurisdiction's election, and there is no consensus among election officials and other experts on their pervasiveness. Nevertheless, some have caused problems in elections and therefore merit attention. Federal organizations and nongovernmental groups have issued both election-specific recommended practices for improving the voting process and more general guidance intended to help organizations manage information systems' security and reliability. These recommended practices and guidelines (applicable throughout the voting system life cycle) include having vendors build security controls and audit trails into their systems during development, and having election officials specify security requirements when acquiring systems. Other suggested practices include testing and certifying systems against national voting system standards. The federal government has begun efforts intended to improve life cycle management of electronic voting systems and thereby improve their security and reliability. Specifically, EAC has led efforts to (1) draft changes to existing federal voluntary standards for voting systems, including provisions addressing security and reliability; (2) develop a process for certifying voting systems; (3) establish a program to accredit independent laboratories to test electronic voting systems; and (4) develop a library and clearinghouse for information on state and local elections and systems. However, these actions are unlikely to have a significant effect in the 2006 federal election cycle because important changes to the voting standards have not yet been completed, the system certification and laboratory accreditation programs are still in development, and a system software library has not been updated or improved since the 2004 election. Further, EAC has not consistently defined specific tasks, processes, and time frames for completing these activities; as a result, it is unclear when their results will be available to assist state and local election officials.
RecommendationsOur recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
Director: Team: Phone:GAO-05-956, Elections: Federal Efforts to Improve Security and Reliability of Electronic Voting Systems Are Under Way, but Key Activities Need to Be Completed
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2005.
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Report to Congressional Requesters:
September 2005:
Elections:
Federal Efforts to Improve Security and Reliability of Electronic
Voting Systems Are Under Way, but Key Activities Need to Be Completed:
[Hyperlink, http://www.gao.gov/cgi-bin/getrpt?GAO-05-956]:
GAO Highlights:
Highlights of GAO-05-956, a report to congressional requesters:
Why GAO Did This Study:
The Help America Vote Act of 2002 established the Election Assistance
Commission (EAC) to help improve state and local administration of
federal elections and authorized funding for state and local
governments to expand their use of electronic voting systems. EAC began
operations in January 2004. However, reported problems with electronic
voting systems have led to questions about the security and reliability
of these systems. GAO was requested to (1) determine the significant
security and reliability concerns identified about electronic voting
systems, (2) identify recommended practices relevant to ensuring the
security and reliability of these systems, and (3) describe actions
taken or planned to improve their security and reliability.
What GAO Found:
While electronic voting systems hold promise for improving the election
process, numerous entities have raised concerns about their security
and reliability, citing instances of weak security controls, system
design flaws, inadequate system version control, inadequate security
testing, incorrect system configuration, poor security management, and
vague or incomplete voting system standards (see below for examples).
It is important to note that many of these concerns were based on
specific system makes and models or a specific jurisdiction‘s election,
and there is no consensus among election officials and other experts on
their pervasiveness. Nevertheless, some have caused problems in
elections and therefore merit attention.
Federal organizations and nongovernmental groups have issued both
election-specific recommended practices for improving the voting
process and more general guidance intended to help organizations manage
information systems‘ security and reliability. These recommended
practices and guidelines (applicable throughout the voting system life
cycle) include having vendors build security controls and audit trails
into their systems during development, and having election officials
specify security requirements when acquiring systems. Other suggested
practices include testing and certifying systems against national
voting system standards.
The federal government has begun efforts intended to improve life cycle
management of electronic voting systems and thereby improve their
security and reliability. Specifically, EAC has led efforts to (1)
draft changes to existing federal voluntary standards for voting
systems, including provisions addressing security and reliability; (2)
develop a process for certifying voting systems; (3) establish a
program to accredit independent laboratories to test electronic voting
systems; and (4) develop a library and clearinghouse for information on
state and local elections and systems. However, these actions are
unlikely to have a significant effect in the 2006 federal election
cycle because important changes to the voting standards have not yet
been completed, the system certification and laboratory accreditation
programs are still in development, and a system software library has
not been updated or improved since the 2004 election. Further, EAC has
not consistently defined specific tasks, processes, and time frames for
completing these activities; as a result, it is unclear when their
results will be available to assist state and local election officials.
Examples of Voting System Vulnerabilities and Problems
* Cast ballots, ballot definition files, and audit logs could be
modified.
* Supervisor functions were protected with weak or easily guessed
passwords.
* Systems had easily picked locks and power switches that were exposed
and unprotected.
* Local jurisdictions misconfigured their electronic voting systems,
leading to election day problems.
* Voting systems experienced operational failures during elections.
* Vendors installed uncertified electronic voting systems.
Source: GAO analysis of recent reports and studies.
[End of table]
What GAO Recommends:
To help ensure the security and reliability of electronic voting
systems, GAO is recommending that EAC define specific tasks, processes,
and time frames for improving the national voting systems standards,
testing capabilities, and management support available to state and
local election officials. In commenting on a draft of this report, EAC
agreed with the recommendations and stated that the commission has
initiatives under way or planned in these areas. The commission also
sought additional clarification and context on reported problems.
www.gao.gov/cgi-bin/getrpt?GAO-05-956.
To view the full product, including the scope and methodology, click on
the link above. For more information, contact David Powner at (202) 512-
9286 or pownerd@gao.gov.
[End of section]
Contents:
Letter:
Results in Brief:
Background:
Significant Concerns Have Been Raised about the Security and
Reliability of Electronic Voting Systems:
Recommended Practices Address Electronic Voting Systems' Security and
Reliability:
National Initiatives Are Under Way to Improve Voting System Security
and Reliability, but Key Activities Need to Be Completed:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: Selected Recommended Practices for Voting System Security
and Reliability:
Appendix III: Summary of Selected Guidance on Information Technology
Security and Reliability:
Appendix IV: Resolutions Related to Voting System Security and
Reliability:
Appendix V: Comments from the Election Assistance Commission:
Appendix VI: Comments from the National Institute of Standards and
Technology:
Appendix VII: GAO Contacts and Staff Acknowledgments:
Bibliography:
Tables:
Table 1: Common Types of Security and Reliability Concerns Viewed in
Terms of the Voting System Life Cycle:
Table 2: Federal Initiatives Related to Improving the Security and
Reliability of Voting Systems:
Table 3: Nongovernmental Initiatives to Improve Voting System Security
and Reliability:
Table 4: EAC Security and Reliability Practices for All Types of Voting
Systems:
Table 5: EAC Security and Reliability Practices for Optical Scan Voting
Systems:
Table 6: EAC Security and Reliability Practices for Direct Recording
Electronic Voting Systems:
Table 7: NIST Security and Reliability Practices for Electronic Voting
Systems:
Table 8: Brennan Center Example Security and Reliability Practices for
Direct Recording Electronic Voting Systems:
Table 9: Election Center Security and Reliability Practices for
Elections:
Table 10: National Task Force on Election Reform Security and
Reliability Practices for Voting Systems:
Table 11: Caltech/MIT Security and Reliability Practices for Voting
Systems:
Table 12: Caltech/MIT Security and Reliability Practices for Electronic
Voting Systems:
Table 13: League of Women Voters Security and Reliability Practices for
All Voting Systems:
Table 14: League of Women Voters Security and Reliability Practices for
Optical Scan Voting Systems:
Table 15: League of Women Voters Security and Reliability Practices for
Direct Recording Electronic Voting Systems:
Table 16: A Compendium of Recommended Mitigation Measures to Address
Selected Concerns with Electronic Voting Systems' Security and
Reliability:
Table 17: Examples of NIST Publications Addressing System Security and
Reliability:
Table 18: Resolutions Related to Security and Reliability of Electronic
Voting Systems and Plans for Implementing Them in Future Standards:
Figures:
Figure 1: Stages of an Election Process:
Figure 2: Precinct-Count Optical Scan Tabulator and Central-Count
Optical Scan Tabulator:
Figure 3: Two Types of DRE Systems--Pushbutton and Touchscreen:
Figure 4: States Requiring the Use of Federal Voting System Standards
and States Requiring National Certification Testing:
Figure 5: A Voting System Life Cycle Model:
Abbreviations:
COTS: commercial off-the-shelf:
DRE: Direct Recording Electronic:
EAC: Election Assistance Commission:
HAVA: Help America Vote Act:
IT: information technology:
NIST: National Institute of Standards and Technology:
TGDC: Technical Guidelines Development Committee:
Letter September 21, 2005:
Congressional Requesters:
After the 2000 elections, Congress, the media, and others cited
numerous instances of problems with the election process. In light of
these concerns, we produced a series of reports in which we examined
virtually every aspect of the election process, including challenges
associated with electronic voting systems.[Footnote 1] In these
reports, we emphasized the contributions and necessary interactions of
people, process, and technology to address these challenges.
Subsequently, in October 2002, Congress passed the Help America Vote
Act (HAVA), which authorized funding for local and state governments to
make improvements in election administration, including upgrading
antiquated voting systems. In addition, HAVA created the Election
Assistance Commission (EAC) to provide support for election
improvements and to administer payments to states under the act. As
states have expanded their use of electronic voting systems, the media
and others have reported problems with these systems that have caused
some to question whether they are secure and reliable.
In view of the importance and growing role of electronic voting
systems, you asked us to (1) determine the significant security and
reliability concerns that have been identified about these voting
systems; (2) identify recommended practices relevant to ensuring the
security and reliability of such systems; and (3) describe the actions
that federal agencies and other organizations have taken, or plan to
take, to improve their security and reliability. To determine concerns
and recommended practices, we analyzed over 80 recent and relevant
reports related to the security and reliability of electronic voting
systems. We focused on systems and components associated with vote
casting and counting, including those that define electronic ballots,
transmit voting results among election locations, and manage groups of
voting machines. We assessed the various types of voting system issues
reported to determine categories of concerns. We discussed the reports,
concerns, and recommended practices with elections officials, citizen
advocacy groups, and system security and testing experts, including
members of GAO's Executive Council on Information Management and
Technology.[Footnote 2] To describe actions to improve the security and
reliability of electronic voting systems, we reviewed and analyzed
pertinent documentation, such as EAC's draft voluntary voting system
guidelines (which are expected to replace the 2002 voting system
standards), and we attended public meetings and interviewed officials
from EAC, its Technical Guidelines Development Committee (TGDC), and
the Department of Commerce's National Institute of Standards and
Technology (NIST). We also identified activities being performed by
citizen advocacy groups, academic and standards bodies, and others that
are intended to improve the security and reliability of electronic
voting systems, reviewed materials from these activities, and discussed
them with representatives of these groups. Appendix I provides
additional details on our objectives, scope, and methodology. We
performed our work from January through August 2005 in the Washington,
D.C., metropolitan area, in accordance with generally accepted
government auditing standards.
Results in Brief:
While electronic voting systems hold promise for a more accurate and
efficient election process, numerous entities have raised concerns
about their security and reliability, citing instances of weak security
controls, system design flaws, inadequate system version control,
inadequate security testing, incorrect system configuration, poor
security management, and vague or incomplete voting system standards,
among other issues. For example, studies found (1) some electronic
voting systems did not encrypt cast ballots or system audit logs, and
it was possible to alter both without being detected; (2) it was
possible to alter the files that define how a ballot looks and works so
that the votes for one candidate could be recorded for a different
candidate; and (3) vendors installed uncertified versions of voting
system software at the local level. It is important to note that many
of the reported concerns were drawn from specific system makes and
models or from a specific jurisdiction's election, and that there is a
lack of consensus among election officials and other experts on the
pervasiveness of the concerns. Nevertheless, some of these concerns
were reported to have caused local problems in federal elections--
resulting in the loss or miscount of votes--and therefore merit
attention.
Federal organizations and nongovernmental groups have issued
recommended practices and guidance for improving the election process,
including electronic voting systems, as well as general practices for
the security and reliability of information systems. For example, in
mid-2004, EAC issued a compendium of practices recommended by election
experts, including state and local election officials.[Footnote 3] This
compendium includes approaches for making voting processes more secure
and reliable through, for example, risk analysis of the voting process,
poll worker security training, and chain of custody controls for
election day operations, along with practices that are specific to
ensuring the security and reliability of different types of electronic
voting systems. As another example, in July 2004, the California
Institute of Technology and the Massachusetts Institute of Technology
issued a report containing recommendations pertaining to testing
equipment, retaining audit logs, and physically securing voting
systems.[Footnote 4] In addition to such election-specific practices,
numerous recommended practices are available that can be applied to any
information system. For instance, we, NIST, and others have issued
guidance that emphasizes the importance of incorporating security and
reliability into the life cycle of information systems through
practices related to security planning and management, risk management,
and procurement.[Footnote 5] The recommended practices in these
election-specific and information technology (IT) focused documents
provide valuable guidance that, if implemented effectively, should help
improve the security and reliability of voting systems.
Since the passage of HAVA in 2002, the federal government has begun a
range of actions that are expected to improve the security and
reliability of electronic voting systems. Specifically, after beginning
operations in January 2004, EAC has led efforts to (1) draft changes to
the existing federal voluntary standards[Footnote 6] for voting
systems, including provisions related to security and reliability, (2)
develop a process for certifying, decertifying, and recertifying voting
systems, (3) establish a program to accredit the national independent
testing laboratories that test electronic voting systems against the
federal voluntary standards, and (4) develop a software library and
clearinghouse for information on state and local elections and systems.
However, these actions are unlikely to have a significant effect in the
2006 federal election cycle because the changes to the voluntary
standards have not yet been completed, the system certification and
laboratory accreditation programs are still in development, and the
software library has not been updated or improved since the 2004
elections. Further, EAC has not defined tasks, processes, and time
frames for completing these activities. As a result, it is unclear when
the results will be available to assist state and local election
officials. In addition to the federal government's activities, other
organizations have actions under way that are intended to improve the
security and reliability of electronic voting systems. These actions
include developing and obtaining international acceptance for voting
system standards, developing voting system software in an open source
environment (i.e., not proprietary to any particular company), and
cataloging and analyzing reported problems with electronic voting
systems.
To improve the security and reliability of electronic voting systems,
we are recommending that EAC establish tasks, processes, and time
frames for improving the federal voluntary voting system standards,
testing capabilities, and management support available to state and
local election officials.
EAC and NIST provided written comments on a draft of this report (see
apps. V and VI). EAC commissioners agreed with our recommendations and
stated that actions on each are either under way or intended. NIST's
director agreed with the report's conclusions. In addition to their
comments on our recommendations, EAC commissioners expressed three
concerns with our use of reports produced by others to identify issues
with the security and reliability of electronic voting systems.
Specifically, EAC sought (1) additional clarification on our sources,
(2) context on the extent to which voting system problems are systemic,
and (3) substantiation of claims in the reports issued by others. To
address these concerns, we provided additional clarification of sources
where applicable. Further, we note throughout our report that many
issues involved specific system makes and models or circumstances in
the elections of specific jurisdictions. We also note that there is a
lack of consensus on the pervasiveness of the problems, due in part to
a lack of comprehensive information on what system makes and models are
used in jurisdictions throughout the country. Additionally, while our
work focused on identifying and grouping problems and vulnerabilities
identified in issued reports and studies, where appropriate and
feasible, we sought additional context, clarification, and
corroboration from experts, including election officials, security
experts, and key reports' authors. EAC commissioners also expressed
concern that we focus too much on the commission, and noted that it is
one of many entities with a role in improving the security and
reliability of voting systems. While we agree that EAC is one of many
entities with responsibilities for improving the security and
reliability of voting systems, we believe that our focus on EAC is
appropriate, given its leadership role in defining voting system
standards, in establishing programs both to accredit laboratories and
to certify voting systems, and in acting as a clearinghouse for
improvement efforts across the nation. EAC and NIST officials also
provided detailed technical corrections, which we incorporated
throughout the report as appropriate.
Background:
All levels of government share responsibility in the U.S. election
process. At the federal level, Congress has authority under the
Constitution to regulate presidential and congressional elections and
to enforce prohibitions against specific discriminatory practices in
all federal, state, and local elections. Congress has passed
legislation that addresses voter registration, absentee voting,
accessibility provisions for the elderly and handicapped, and
prohibitions against discriminatory practices.[Footnote 7]
At the state level, individual states are responsible for the
administration of both federal elections and their own elections.
States regulate the election process, including, for example, the
adoption of voluntary voting system guidelines, the state certification
and acceptance testing of voting systems, ballot access, registration
procedures, absentee voting requirements, the establishment of voting
places, the provision of election day workers, and the counting and
certification of the vote. In total, the U.S. election process can be
seen as an assemblage of 55 distinct election systems--those of the 50
states, the District of Columbia, and the 4 U.S. territories.
Further, although election policy and procedures are legislated
primarily at the state level, states typically have decentralized
voting processes, so that the details of administering elections are
carried out at the city or county levels, and voting is done at the
local level. As we reported in 2001, local election jurisdictions
number more than 10,000, and their sizes vary enormously--from a rural
county with about 200 voters to a large urban county, such as Los
Angeles County, where the total number of registered voters for the
2000 elections exceeded the registered voter totals in 41
states.[Footnote 8]
Administering an election is a year-round process involving the
following stages:
* Voter registration. Local election officials register eligible voters
and maintain voter registration lists. This includes updating
registrants' information and deleting the names of registrants who are
no longer eligible to vote.
* Absentee and early voting. Election officials design ballots and
other systems to permit eligible people to vote in person or by mail
before election day. Election officials also educate voters on how to
vote by these methods.
* Election administration and vote casting. Election officials prepare
for an election by arranging for polling places, recruiting and
training poll workers, designing ballots, and preparing and testing
voting equipment for use in casting and tabulating votes. Election day
activities include opening and closing polling places and assisting
voters in casting votes.
* Vote counting and certification. Election officials tabulate the cast
ballots, determine whether and how to count ballots that cannot be read
by the vote counting equipment, certify the final vote counts, and
perform recounts, if required.
As shown in figure 1, each stage of an election involves people,
processes, and technology.
Figure 1: Stages of an Election Process:
[See PDF for image]
[End of figure]
Electronic Voting Systems Support Vote Casting and Counting:
Electronic voting systems hold promise for improving the efficiency and
accuracy of the election process by automating a manual process,
providing flexibility for accommodating voters with special needs, and
implementing controls to avoid errors by voters and election workers.
In the United States today, most votes are cast and counted by one of
two types of electronic voting systems: optical scan systems and direct
recording electronic (DRE) systems. Such systems include the hardware,
software, and firmware used to define ballots, cast and count votes,
report or display election results, and maintain and produce audit
trail information--as well as the documentation required to program,
control, and support the equipment. A description of both technologies
follows.
Optical Scan Systems. Optical scan voting systems use electronic
technology to tabulate paper ballots. Although optical scan technology
has been in use for decades for such tasks as scoring standardized
tests, it was not applied to voting until the 1980s. According to
Election Data Services, Inc., a firm specializing in election data
statistics, about 31 percent of registered voters voted on optical scan
systems in the 2000 election, and about 35 percent of registered voters
voted on optical scan systems in the 2004 election.
An optical scan system is made up of computer-readable paper ballots,
appropriate marking devices, privacy booths, and a computerized
tabulation device. The ballot, which can be of various sizes, lists the
names of the candidates and the issues. Voters record their choices
using an appropriate writing instrument to fill in boxes or ovals, or
to complete an arrow next to a candidate's name or the issue. In some
states, the ballot may include a space for write-ins to be entered
directly on the ballot.
Optical scan ballots are tabulated by optical-mark-recognition
equipment (see fig. 2), which counts the ballots by sensing or reading
the marks on the ballot. Ballots can be counted at the polling place--
referred to as a precinct-count optical scan[Footnote 9]--or at a
central location. If ballots are counted at the polling place, voters
or election officials put the ballots into the tabulation equipment,
which tallies the votes; these tallies can be captured in removable
storage media that are transported to a central tally location, or they
can be electronically transmitted from the polling place to the central
tally location. If ballots are centrally counted, voters drop ballots
into sealed boxes and election officials transfer the sealed boxes to
the central location after the polls close, where election officials
run the ballots through the tabulation equipment in the presence of
observers.
Figure 2: Precinct-Count Optical Scan Tabulator and Central-Count
Optical Scan Tabulator:
[See PDF for image]
[End of figure]
Software instructs the tabulation equipment how to assign each vote
(i.e., to assign valid marks on the ballot to the proper candidate or
issue). In addition to identifying the particular contests and
candidates, the software can be configured to capture, for example,
straight party voting and vote-for-no-more-than-N contests. Precinct-
based optical scanners can also be programmed to detect overvotes
(where the voter votes for two candidates for one office, for example,
invalidating the vote) and undervotes (where the voter does not vote
for all contests or issues on the ballot) and to take some action in
response (rejecting the ballot, for instance). In addition, optical
scan systems often use vote-tally software to tally the vote totals
from one or more vote tabulation devices.
If election officials program precinct-based optical scan systems to
detect and reject overvotes and undervotes, voters can fix their
mistakes before leaving the polling place. However, if voters are
unwilling or unable to correct their ballots, a poll worker can
manually override the program and accept the ballot, even though it has
been overvoted or undervoted. If ballots are tabulated centrally,
voters would not be able to correct any mistakes that may have been
made.
Direct Recording Electronic (DRE) Systems. First introduced in the
1970s, DREs capture votes electronically, without the use of paper
ballots. According to Election Data Services, Inc., about 12 percent of
voters used this type of technology in the 2000 elections and about 29
percent of voters used this technology in the 2004 elections.
DREs come in two basic models: pushbutton or touchscreen. The
pushbutton model is the older technology and is larger and heavier than
the touchscreen model (see fig. 3).
Figure 3: Two Types of DRE Systems--Pushbutton and Touchscreen:
[See PDF for image]
[End of figure]
Pushbutton and touchscreen models also differ significantly in the way
they present ballots to the voter. With the pushbutton model, all
ballot information is presented on a single "full-face" ballot. For
example, a ballot may have 50 buttons on a 3-by 3-foot ballot, with a
candidate or issue next to each button. In contrast, touchscreen DREs
display the ballot information on an electronic display screen. For
both pushbutton and touchscreen models, the ballot information is
programmed onto an electronic storage medium, which is then uploaded to
the machine. Both models rely on ballot definition files to tell the
voting machine software how to display ballot information on the
screen, interpret a voter's touches on a button or screen, and record
and tally those selections as votes. Local jurisdictions can program
these files before each election or outsource their programming to a
vendor. For touchscreens, ballot information can be displayed in color
and can incorporate pictures of the candidates. Because the ballot
space on a touchscreen is much smaller than on a pushbutton machine,
voters who use touchscreens must page through the ballot information.
Despite their differences, the two DRE models have some similarities,
such as how the voter interacts with the voting equipment. For
pushbutton models, voters press a button next to the candidate or
issue, which then lights up to indicate the selection. Similarly,
voters using touchscreens make their selections by touching the screen
next to the candidate or issue, which is then highlighted. When voters
have finished making their selections on a touchscreen or a pushbutton
model, they cast their votes by pressing a final "vote" button or
screen. Until they hit this final button or screen, voters can change
their selections. Both models also allow voters to write in candidates.
While most DREs allow voters to type write-ins on a keyboard, some
pushbutton types require voters to write the name on paper tape that is
part of the device. Further, although these systems do not use paper
ballots, they retain permanent electronic images of all the ballots,
which can be stored on various media, including internal hard disk
drives, flash cards, or memory cartridges. According to vendors, these
ballot images can be printed and used for auditing and recounts.
Some of the newer DREs use smart cards as a security feature. Smart
cards are plastic devices--about the size of a credit card--that use
integrated circuit chips to store and process data, much like a
computer. These cards are generally used as a means to open polls and
to authorize voter access to ballots. For instance, smart cards for
some systems store program data on the election and are used to help
set up the equipment; during setup, election workers verify that the
card is for the proper election. Other systems are programmed to
automatically activate when the voter inserts a smart card; the card
brings up the correct ballot onto the screen. In general, the interface
with the voter is very similar to that of an automated teller machine.
Like optical scan devices, DREs require the use of software to program
the various ballot styles and tally the votes, which is generally done
through the use of memory cartridges or other media. The software is
used to generate ballots for each precinct in the voting jurisdiction,
which includes defining the ballot layout, identifying the contests in
each precinct, and assigning candidates to contests. The software also
is used to configure any special options, such as straight party voting
and vote-for-no-more-than-N contests. In addition, for pushbutton
models, the software assigns the buttons to particular candidates, and,
for touchscreen models, the software defines the size and location on
the screen where the voter makes the selection. Vote-tally software is
often used to tally the vote totals from one or more units.
DRE systems offer various configurations for tallying the votes. Some
contain removable storage media that can be taken from the voting
device and transported to a central location to be tallied. Others can
be configured to electronically transmit the vote totals from the
polling place to a central tally location.
These systems are also designed not to allow overvotes. For example, if
a voter selects a second choice in a two-way race, the first choice is
deselected. In addition to this standard feature, different types of
systems offer a variety of options, including many aimed at voters with
disabilities. In our prior work,[Footnote 10] we reported that the
following features were available on some models of DRE:
* A "no-vote" option. If allowed by the state, this option helps avoid
unintentional undervotes. This provides the voter with the option to
select "no vote" (or abstain) on the display screen if the voter does
not want to vote on a particular contest or issue.
* A "review" feature. This feature requires voters to review each page
of the ballot before pressing the button to cast the vote.
* Visual enhancements. These features include, for example, color
highlighting of ballot choices and candidate pictures.
* Accommodations for voters with disabilities. Examples of options for
voters who are blind include Braille keyboards and audio
interfaces.[Footnote 11] At least one vendor reported that its DRE
accommodates voters with neurological disabilities by offering head
movement switches and "sip and puff" plug-ins.[Footnote 12] Another
option is voice recognition capability, which allows voters to make
selections orally.
* An option to recover spoiled ballots. This feature allows voters to
recast their votes after their original ballots are cast. For this
option, every DRE at the poll site could be connected to a local area
network. A poll official would void the original "spoiled" ballot
through the administrative workstation, which is also connected to the
local area network. The voter could then cast another ballot.
* An option to provide printed receipts. This option, provided by a
voter-verified paper audit trail system, provides the voter with a
paper printout or ballot when the vote is cast. This feature is
intended to provide voters and/or election officials with an
opportunity to check what is printed against what is recorded and
displayed.
HAVA Is Expected to Enhance the Federal Role in Election Processes:
In October 2002, Congress passed the Help America Vote Act (HAVA) to
provide states with organizations, processes, and resources for
improving the administration of future federal elections. The act also
specified time frames for the availability of these organizations,
processes, and resources. The act was intended, among other things, to
encourage states to upgrade antiquated voting systems and technologies
and to support the states in making federally mandated improvements to
their voting systems, such as ensuring that voters can verify their
votes before casting their ballot, providing records for manual
auditing of voting systems, and establishing maximum error rates for
counting ballots.
Organizations. HAVA established the Election Assistance Commission
(EAC) and gave this commission responsibility for activities and
programs related to the administration of federal elections. This
independent federal agency consists of four presidential appointees
confirmed by the Senate, as well as support staff, including personnel
inherited from the former Office of Election Administration of the
Federal Election Commission. EAC commissioners were appointed in
December 2003, and the commission began operations in January 2004. EAC
is intended to serve as a national clearinghouse and resource for the
compilation of information and procedures on election administration.
Its responsibilities relative to voting systems include:
* adopting and maintaining voluntary voting system guidelines;
* managing a national program for testing, certification,
decertification, and recertification of voting system hardware and
software;
* maintaining a clearinghouse of information on the experiences of
state and local governments in implementing the guidelines and
operating voting systems; and:
* conducting studies and other activities to promote effective
administration of federal elections.
HAVA also established three organizations and levied new requirements
on a fourth to assist EAC in establishing voting system standards and
performing its responsibilities, including standards and
responsibilities involving the security and reliability of voting
systems:
* The Technical Guidelines Development Committee (TGDC) is to assist
EAC in developing voluntary voting system standards (which are now
called guidelines). This committee includes selected state and local
election officials and representatives of professional and technical
organizations. It is chaired by the Director of the National Institute
of Standards and Technology.
* The Standards Board brings together one state and one local official
from each of the 55 states and territories to review the voluntary
voting system guidelines developed by TGDC and provide comments and
recommendations on the guidelines to EAC.
* The Board of Advisors is made up of 37 members--many from various
professional and specialty organizations.[Footnote 13] Like the
Standards Board, the Board of Advisors reviews the voluntary voting
system guidelines developed by TGDC and provides comments and
recommendations to EAC.
* The Department of Commerce's National Institute of Standards and
Technology (NIST) provides technical support to TGDC, including
research and development of the voting system guidelines. NIST is also
responsible for monitoring and reviewing the performance of independent
testing laboratories (previously known as independent testing
authorities) and making recommendations for accreditation and
revocation of accreditation of the laboratories by EAC. NIST's
responsibilities for improving the security and reliability of
electronic voting systems include identification of security and
reliability standards for voting system computers, networks, and data
storage; methods to detect and prevent fraud; and protections for voter
privacy and remote voting system access.
Processes. HAVA provides for three major processes related to the
security and reliability of voting systems: updating voluntary
standards, accrediting independent testing laboratories, and certifying
voting systems to meet national standards. HAVA specifies the
organizations involved, activities to be undertaken, public visibility
for the processes, and, in some cases, work products and deadlines.
These processes are described below.
* Updating standards. EAC and TGDC were given responsibility for
evaluating and updating the Federal Election Commission's voluntary
voting system standards of 2002. TGDC is to propose standards changes
within 9 months of the appointment of all of its members, and EAC is to
hold a public hearing and a comment period for the standards changes
and allow at least 90 days for review and comment by the standards and
advisory boards before voting on the standards. EAC and its boards are
also to consider updates to the standards on an annual basis.
* Accrediting laboratories. NIST's director is charged with evaluating
the capabilities of independent nonfederal laboratories to carry out
certification testing of voting systems within 6 months after EAC
adopts the first update to the voluntary voting system
standards.[Footnote 14] Through its National Voluntary Laboratory
Accreditation Program, NIST is to recommend qualified laboratories for
EAC's accreditation, provide ongoing monitoring and reviews of the
accredited laboratories, and recommend revocation of accreditation, if
necessary.
* Certifying systems. EAC is to establish processes for certifying,
decertifying, and recertifying voting systems. HAVA allows the current
processes (as conducted under the National Association of State
Election Directors) to continue until the laboratory accreditation
processes to be developed by NIST are established and laboratories are
accredited by EAC to conduct certification testing. States may also use
the nationally accredited testing laboratories for testing associated
with certification, decertification, and recertification of voting
systems to meet state certification requirements.
The majority of states currently rely on federal standards, but do not
require national certification testing to ensure that voting systems
meet functional, performance, and quality goals. On the basis of an
April 2005 review of state statutes and administrative rules, EAC
identified at least 30 states that require their voting systems to meet
federal standards issued by the Federal Election Commission, EAC, or
both (see fig. 4). As for certification, the majority of states require
state certification of voting systems, but do not require national
testing. Only 13 states currently require their systems to be tested
against the federal standards by independent testing authorities and
certified by the National Association of State Election Directors (see
fig. 4). In commenting on a draft of this report, EAC noted that some
state and local jurisdictions can choose to exceed state statute and
administrative rules--and may be using federal standards and national
certification testing.
Figure 4: States Requiring the Use of Federal Voting System Standards
and States Requiring National Certification Testing:
[See PDF for image]
Note: State requirements are based on EAC assessment of state statute
and administrative rule.
[End of figure]
Resources. HAVA authorized federal payments to help states improve
their voting systems in two ways:
* By replacing punch card and lever voting systems in time for the
November 2004 federal election unless a waiver authorizing a delay is
granted by the Administrator of the General Services Administration. In
the event of a waiver, states are required to replace the systems in
time for the first federal election held after January 1,
2006.[Footnote 15] EAC reports that approximately $300 million was
distributed to 30 states under this HAVA provision--all in fiscal year
2003.
* By incorporating new voting system functions required by HAVA (for
instance, ballot verification by voters, producing printed records for
election auditing, and meeting vote counting error rates);[Footnote 16]
upgrading systems in general; improving the administration of
elections; or educating voters and training election workers (among
other things).[Footnote 17] EAC reported that as of August 31, 2005,
approximately $2.5 billion had been disbursed to the 50 states, 4 U.S.
territories, and the District of Columbia, for these and other election
improvements.
Time frames. HAVA specifies time frames for several key activities.
Specifically, it requires that:
* EAC commissioners be appointed no later than 120 days after the law
was enacted,
* a program to distribute payments to states to replace antiquated
voting systems be in place no later than 45 days after the law was
enacted,
* the first set of recommendations for revising the voluntary voting
system standards be submitted to EAC no later than 9 months after the
appointment of TGDC members,
* EAC approve voluntary guidance for certain voting system standards by
January 2004,
* NIST conduct evaluations of independent testing laboratories for
accreditation within 6 months of the adoption of updated voting
standards,
* states receiving federal payments replace their lever or punch card
voting machines in time for the November 2004 federal election, or the
first federal election after January 2006, with a waiver, and:
* states meet requirements for federally mandated improvements to
voting systems, such as voter verification of ballots, records for
manual audits, and maximum error rates for ballot counts (HAVA Section
301) by January 1, 2006.
EAC commissioners were appointed in December 2003--over a year after
the law was enacted--and the commission began operations in January
2004. It received $1.2 million in funding in fiscal year 2004
increasing to $14 million in fiscal year 2005. Thus, the commission got
a late start on its initiatives. As discussed later in this report, key
activities are currently under way.
Security and Reliability Are Important Elements Throughout the Voting
System Life Cycle:
Electronic voting systems are typically developed by vendors and then
purchased commercially off the shelf and operated by state and local
election administrators. Viewed at a high level, these activities make
up three phases of a system life cycle: product development,
acquisition, and operations (see fig. 5). Key processes that span these
life cycle phases include managing the people, processes, and
technologies within each phase, and testing the systems and components
during and at the end of each phase. Additionally, voting system
standards are important through all of the phases because they provide
criteria for developing, testing, and acquiring voting systems, and
they specify the necessary documentation for operating the systems. As
with other information systems, it is important to build principles of
security and reliability into each phase of the voting system life
cycle.
Figure 5: A Voting System Life Cycle Model:
[See PDF for image]
[End of figure]
The product development phase includes activities such as establishing
requirements for the system, designing a system architecture, and
developing software and integrating components. Activities in this
phase are performed by the system vendor. Design and development
activities related to security and reliability of electronic voting
systems include such things as requirements development and hardware
and software design.
The acquisition phase covers activities for procuring voting systems
from vendors such as publishing a request for proposal, evaluating
proposals, choosing a voting technology, choosing a vendor, and writing
and administering contracts. For voting systems, activities in this
phase are primarily the responsibility of state and local governments,
but entail some responsibilities that are shared with the system vendor
(such as establishing contractual agreements). Acquisition activities
affecting the security and reliability of electronic voting systems
include such things as specifying provisions for security controls in
contracts and identifying evaluation criteria for prospective systems.
The operations phase consists of activities for operating the voting
systems, including the setup of systems before voting, vote capture and
counting during elections, recounts and system audits after elections,
and storage of systems between elections. Responsibility for activities
in this phase typically resides with local jurisdictions. Security and
reliability aspects of this phase include physical security of the
polling place and voting equipment, chain of custody for voting system
components and supplies, system audit logs and backups, and the
collection, analysis, reporting, and resolution of election problems.
Standards for voting systems were developed at the national level by
the Federal Election Commission in 1990 and 2002 and are now being
updated by EAC, TGDC, and NIST. Voting system standards affect all life
cycle phases. In the product development phase, they serve as guidance
for developers to build systems. In the acquisition phase, they provide
a framework that state and local governments can use to evaluate
systems. In the operations phase, they specify the necessary
documentation for operating the systems. Current and planned national
standards include explicit requirements for ensuring the security and
reliability of voting systems.
Testing processes are conducted throughout the life cycle of a voting
system. Voting system vendors conduct product testing during
development of the system and its components. National testing of
products submitted by system vendors is conducted by nationally
accredited independent testing authorities. States may conduct
evaluation testing before acquiring a system to determine how well
products meet their specifications, or may conduct certification
testing to ensure that a system performs its functions as specified by
state laws and requirements. Once a voting system is delivered by the
system vendor, states and local jurisdictions may conduct acceptance
testing to ensure that the system satisfies functional requirements.
Finally, local jurisdictions typically conduct logic and accuracy tests
related to each election, and sometimes subject portions of the system
to parallel testing during each election to ensure that the system
components perform accurately. All of these tests should address system
security and reliability.
Management processes ensure that each life cycle phase produces
desirable outcomes. Typical management activities that span the system
life cycle include planning, configuration management, system
performance review and evaluation, problem tracking and correction,
human capital management, and user training. These activities are
conducted by the responsible parties in each life cycle phase.
Management processes related to security and reliability include
program planning, disaster recovery and contingency planning,
definition of security roles and responsibilities, configuration
management of voting system software and hardware, and poll worker
security training.
In 2004, we reported that the performance of electronic voting systems,
like any type of automated information system, can be judged on several
bases, including how well its design provides for security, accuracy,
ease of use, efficiency, and cost.[Footnote 18] We also reported that
voting system performance is a function of how it was designed and
developed, whether the system performs as designed, and how the system
is implemented. In implementing a system, it is critical to have people
with the requisite knowledge and skills to operate it according to well-
defined and understood processes.
Significant Concerns Have Been Raised about the Security and
Reliability of Electronic Voting Systems:
Electronic voting systems hold promise for improving the efficiency and
accuracy of the election process by automating a manual process,
providing flexibility for accommodating voters with special needs, and
implementing controls to avoid errors by voters and election workers.
However, in a series of recent reports, election officials, computer
security experts, citizen advocacy groups, and others have raised
significant concerns about the security and reliability of electronic
voting systems, citing instances of weak security controls, system
design flaws, inadequate system version control, inadequate security
testing, incorrect system configuration, poor security management, and
vague or incomplete standards, among other issues. Most of the issues
can be viewed in the context of the voting system life cycle, including
(1) the development of voting systems, including the design of these
systems and the environments in which they were developed; (2) the
nature and effectiveness of the testing program for electronic voting
systems; (3) the operation and management of electronic voting systems
at the state and local levels; and (4) the voluntary voting systems
standards, which govern different activities at different phases. The
aspects of the life cycle are interdependent--that is, a problem
experienced in one area of the life cycle will likely affect the other
areas. For example, a weakness in system standards could result in a
poorly designed system during the development phase, which then
malfunctions in the operational phase. Also, each of the life cycle
phases depends on the management of people, processes, and technology
to ensure that they are executed in a manner that adequately ensures
reliable and secure results. Because of these multiple
interdependencies, it is sometimes difficult to determine the root
cause of some problems. Table 1 provides a summary of the different
types of concerns identified.
In viewing these concerns, it is important to note that many involved
vulnerabilities or problems with specific voting system makes and
models or circumstances in a specific jurisdiction's election, and that
there is a lack of consensus among elections officials, computer
security experts, and others on the pervasiveness of the concerns.
Nevertheless, there is evidence that some of these concerns have been
realized and have caused problems with recent elections, resulting in
the loss and miscount of votes. In light of the recently demonstrated
voting system problems; the differing views on how widespread these
problems are; and the complexity of assuring the accuracy, integrity,
confidentiality, and availability of voting systems throughout their
life cycles, the security and reliability concerns raised in recent
reports merit the focused attention of federal, state, and local
authorities responsible for election administration.
Table 1: Common Types of Security and Reliability Concerns Viewed in
Terms of the Voting System Life Cycle:
Life cycle component: Product development;
Common concerns:
* Weak system security controls;
* Design flaws in voter-verified paper audit trail systems;
* Weak security management practices.
Life cycle component: Acquisition;
Common concerns: No significant concerns reported.
Life cycle component: Operations;
Common concerns:
* Incorrect system configuration;
* Poor implementation of security procedures;
* System failures during elections.
Life cycle component: Standards;
Common concerns:
* Vague and incomplete security provisions;
* Inadequate provisions for commercial off-the-shelf systems and
telecommunications and networking services;
* Inadequate requirements for vendor documentation.
Life cycle component: Testing;
Common concerns:
* Inadequate security testing;
* Lack of transparency in the testing process.
Life cycle component: Management;
Common concerns:
* Poor version control of system software;
* Inadequate security management.
Source: GAO analysis and summary.
[End of table]
Common concerns as well as examples of the problems identified during
recent elections are discussed in more detail below.
Product Development:
Multiple recent reports, including several state-commissioned technical
reviews and security assessments, voiced concerns about the development
of secure and reliable electronic voting systems by system vendors.
Three major areas of concern are weak security controls, audit trail
design flaws, and weak security management practices.
Weak system security controls. Some electronic voting systems provided
weak system security controls over key components (including electronic
storage for votes and ballots, remote system access equipment, and
system event and audit logs), access to the systems, and the physical
system hardware.
* Regarding key software components, several evaluations demonstrated
that election management systems did not encrypt the data files
containing cast votes (to protect them from being viewed or
modified).[Footnote 19] Evaluations also showed that, in some cases,
other computer programs could access these cast vote files and alter
them without the system recording this action in its audit
logs.[Footnote 20] Two reports documented how it might be possible to
alter the ballot definition files on one model of DRE so that the votes
shown on the touch screen for one candidate would actually be recorded
and counted for a different candidate.[Footnote 21] In addition, one of
these reports found that it was possible to gain full control of a
regional vote tabulation computer--including the ability to modify the
voting software--via a modem connection.[Footnote 22] More recently,
computer security experts working with a local elections supervisor in
Florida demonstrated that someone with physical access to an optical
scan voting system could falsify election results without leaving any
record of this action in the system's audit logs by using altered
memory cards.[Footnote 23] If exploited, these weaknesses could damage
the integrity of ballots, votes, and voting system software by allowing
unauthorized modifications.
* Regarding access controls, many security examinations reported flaws
in how controls were implemented in some DRE systems.[Footnote 24] For
example, one model failed to password-protect the supervisor functions
controlling key system capabilities; another relied on an easily
guessed password to access these functions.[Footnote 25] In another
case, the same personal identification number was programmed into all
supervisor cards nationwide--meaning that the number was likely to be
widely known.[Footnote 26] Reviewers also found that values used to
encrypt election data (called encryption keys) were defined in the
source code.[Footnote 27] Several reviews reported that smart cards
(used to activate the touch screen on DRE systems) and memory cards
(used to program the terminals of optical scan systems) were not
secured by some voting systems. Reviewers exploited this weakness by
altering such cards and using them to improperly access administrator
functions, vote multiple times, change vote totals, and produce false
election reports in a test environment.[Footnote 28] Some election
officials and security experts felt that physical and procedural
controls would detect anyone attempting to vote multiple times during
an actual election.[Footnote 29] Nevertheless, in the event of lax
supervision, the privileges available through these access control
flaws could allow unauthorized personnel to disrupt operations or
modify data and programs that are crucial to the accuracy and integrity
of the voting process.
* Regarding physical hardware controls, several recent reports found
that many of the DRE models under examination contained weaknesses in
controls designed to protect the system. For instance, one report noted
that all the locks on a particular DRE model were easily picked, and
were all controlled by the same keys--keys that the reports' authors
were able to copy at a local store.[Footnote 30] However, the affected
election officials felt that this risk would be mitigated by typical
polling-place supervisors, who would be able to detect anyone picking
the lock on a DRE terminal.[Footnote 31] In another report, reviewers
were concerned that a particular model of DRE was linked together with
others to form a rudimentary network.[Footnote 32] If one of these
machines were accidentally or intentionally unplugged from the others,
voting functions on the other machines in the network would be
disrupted. In addition, reviewers found that the switches used to turn
a DRE system on or off, as well as those used to close the polls on a
particular DRE terminal, were not protected.[Footnote 33]
Design flaws in the voter-verified paper audit trail systems. Voter-
verified paper audit trail systems involve adding a paper printout to a
DRE system that a voter can review and verify. Some citizen advocacy
groups, security experts, and elections officials advocate these
systems as a protection against potential DRE flaws.[Footnote 34]
However, other election officials and researchers have raised concerns
about potential reliability and security flaws in the design of such
systems.[Footnote 35] Critics of the systems argue that adding printers
increases the chance of mechanical failure and disruption to the
polling place.[Footnote 36] Critics also point out that these systems
introduce security risks involving the paper audit trail itself.
Election officials would need to safeguard the paper ballots. If voting
system mechanisms for protecting the paper audit trail were inadequate,
an insider could associate voters with their individual paper ballots
and votes, particularly if the system stored voter-verified ballots
sequentially on a continuous roll of paper.[Footnote 37] If not
protected, such information could breach voter confidentiality.
Weak security management practices. Selected state elections officials,
computer security experts, and election experts view the reported
instances of weak controls as an indication that the voting system
vendors lack strong security management and development
practices.[Footnote 38] Security experts and local election officials
cite the position of trust that vendors occupy in the overall election
process, and say that to ensure the security and reliability of
electronic voting systems--as well as improve voters' confidence in the
electoral process--vendors' practices need to be above
reproach.[Footnote 39] Specific concerns have been expressed about (1)
the personnel security policies used by vendors, including whether
vendors conduct background checks on programmers and systems
developers; (2) whether vendors have established strict internal
security protocols and have adhered to them during software
development; and (3) whether vendors have established clear chain of
custody procedures for handling and transporting their software
securely.[Footnote 40] A committee of election system vendors generally
disagrees with these concerns and asserts that their security
management practices are sound.
Election Operations:
Several reports raised concerns about the operational practices of
local jurisdictions and the performance of their electronic voting
systems during elections. These include incorrect system
configurations, poor implementation of security procedures, and
operational failures during an election.
Incorrect system configuration. Some state and local election reviews
have documented cases in which local governments did not configure
their voting systems properly for an election. For instance, a county
in California presented some voters with an incorrect electronic ballot
in the March 2004 primary.[Footnote 41] As a result, these voters were
unable to vote on certain races. In another case, a county in
Pennsylvania made a ballot programming error on its DRE
system.[Footnote 42] This error contributed to many votes not being
captured correctly by the voting system, evidenced by that county's
undervote percentage, which reached 80 percent in some precincts.
Poor implementation of security procedures. Several reports indicated
that state and local officials did not always follow security
procedures. Reports from Maryland found that a regional vote tabulation
computer was connected to the Internet, and that local officials had
not updated it with several security patches, thus exposing the system
to general security threats.[Footnote 43] In another example, election
monitors in Florida described how certain precincts did not ensure that
the number of votes matched the number of signatures on the precinct
sign-in sheets, thus raising questions as to whether the voting systems
captured the correct number of votes.[Footnote 44] A report from
California cited a number of counties that failed to follow mandatory
security measures set forth by the Secretary of State's office that
were designed to compensate for potential security weaknesses in their
electronic voting systems.[Footnote 45]
System failures during elections. Several state and local jurisdictions
have documented instances when their electronic voting systems
exhibited operational problems during elections. For example,
California officials documented how a failure in a key component of
their system led to polling place disruptions and an unknown number of
disenfranchised voters.[Footnote 46] In another instance, DRE voting
machines in one county in North Carolina continued to accept votes
after their memories were full, effectively causing over 4,000 votes to
be lost.[Footnote 47] The same system was used in Pennsylvania, where
the state's designated voting system examiner noted several other
problems, including the system's failure to accurately capture write-in
or straight ticket votes, screen freezes, and difficulties sensing
voters' touches.[Footnote 48] A Florida county experienced several
problems with its DRE system, including instances where each touch
screen took up to 1 hour to activate and had to be activated separately
and sequentially, causing delays at the polling place.[Footnote 49] In
addition, election monitors discovered that the system contained a flaw
that allowed one DRE system's ballots to be added to the canvass totals
multiple times without being detected.[Footnote 50] In another
instance, a malfunction in a DRE system in Ohio caused the system to
record approximately 3,900 votes too many for one presidential
candidate in the 2004 general election.[Footnote 51] While each of
these problems was noted in an operational environment, the root cause
was not known in all cases.
Standards:
In 1990, the Federal Election Commission issued a set of voluntary
voting systems standards, which were later revised in 2002. These
standards identify minimum functional and performance requirements for
electronic voting systems such as optical scan and DRE voting
equipment. The functional and performance requirements address what
voting equipment should do and delineate minimum performance
thresholds, documentation provisions, and security and quality
assurance requirements. These standards also specify testing to ensure
that the equipment meets these requirements. The standards are
voluntary--meaning that states are free to adopt them in whole or in
part, or reject them entirely.
Computer security experts and others have criticized the 2002 voting
system standards for not containing requirements sufficient to ensure
secure and reliable voting systems. Common concerns with the standards
involve vague and incomplete security provisions, inadequate provisions
for some commercial products and networks, and inadequate documentation
requirements.
Vague and incomplete security provisions. Security experts and others
have criticized the security provisions in the voting system standards
for being vague and lacking specific requirements.[Footnote 52]
Although the standards require the presence of many kinds of security
controls, the concern is that they are not specific enough to ensure
the effective and correct implementation of the controls. One of the
independent testing authorities agreed and noted that the broad terms
of the standards do not provide for consistent testing because they
leave too much room for interpretation.[Footnote 53]
Computer security and testing experts have also noted that the current
voting system standards are not comprehensive enough and that they omit
a number of common computer security controls. For example, an
independent testing authority expressed a concern that the standards do
not prohibit many software coding flaws, which could make the voting
system software susceptible to external attack and malicious
code.[Footnote 54] In addition, NIST performed a review of the voting
system standards and found numerous gaps between its own security
guidance for federal information systems and those prescribed by the
standards. Others have argued that the standards are simply out of
date, and contain no guidance on technologies such as wireless
networking and voter-verified paper audit trails.[Footnote
55]Inadequate provisions for commercial off- the-shelf (COTS) systems
and telecommunications and networking services. Computer security
experts have raised concerns about a provision in the voting system
standards that exempts unaltered COTS software from testing, and about
voting system standards that are not sufficient to address the
weaknesses inherent in telecommunications and networking services.
Specifically, vendors often use COTS software in their electronic
voting systems, including operating systems like Microsoft Windows.
Security experts note that COTS software could contain defects,
vulnerabilities, and other weaknesses that could be carried over into
electronic voting systems, thereby compromising their
security.[Footnote 56] Regarding telecommunication and networking
services, selected computer security experts believe that relying on
any use of telecommunications or networking services, including
wireless communications, exposes electronic voting systems to risks
that make it difficult to guarantee their security and reliability--
even with safeguards such as encryption and digital signatures in
place.[Footnote 57]
Inadequate requirements for documentation. Computer security experts
and some elections officials have expressed concerns that the
documentation requirements in the voting system standards are not
explicit enough. For instance, computer security experts warn that the
documentation requirements for source code are not sufficient for code
that is obscure or confusing, nor do they require developers to
sufficiently map out how software modules interact with one
another.[Footnote 58] This could make it difficult for testers and
auditors to understand what they are reviewing, lessening their ability
to detect unstable or hidden (and potentially malicious) functionality.
In addition, election officials and a security expert raised concerns
that the standards do not require sufficient documentation for local
officials with respect to proper operation and maintenance
procedures.[Footnote 59] For instance, election officials in one state
noted that when voting machines malfunctioned and started generating
error messages during an election, state technicians were unable to
diagnose and resolve the problems because the vendor's documentation
provided no information about what the error messages meant, or how to
fix the problems.[Footnote 60]
Voting System Testing:
Security experts and some election officials have expressed concerns
that tests currently performed by independent testing authorities and
state and local election officials do not adequately assess electronic
voting systems' security and reliability. These concerns are amplified
by what some perceive as a lack of transparency in the testing process.
Inadequate security testing. Many computer security experts expressed
concerns with weak or insufficient system functional testing, source
code reviews, and penetration testing.[Footnote 61] Illustrating their
concerns, most of the systems with weak security controls identified
earlier in this report (see product development issues) had previously
been certified by the National Association of State Election Directors
after testing by an independent testing authority. Security experts and
others point to this as an indication that both the standards and the
testing program are not rigorous enough with respect to security.
* Regarding the functional testing conducted by independent testing
authorities and state and local officials, election and security
experts expressed concern that this testing may not reveal certain
security flaws in electronic voting systems.[Footnote 62] They argue
that functional tests only measure a system's performance when it is
used as expected, under normal operating conditions.[Footnote 63] As a
result, this testing cannot determine what might happen if a voter acts
in unexpected ways, or how the system would react in the face of an
active attack. Specifically, security experts argue that functional
testing is unlikely to ever trigger certain types of hidden
code.[Footnote 64] As a result, malicious code could be present in a
system and evade testing as long as the triggering commands were not
entered.
* Security and testing experts also expressed concern that the source
code reviews called for in the voting system standards and conducted by
independent testing authorities are too general and do not take into
account the unique nature of voting systems. For instance, several
experts noted that malicious code could be hidden in source code and be
obscure enough to avoid detection by the general reviews, which
currently focus on coding conventions, comments, and line
length.[Footnote 65] Moreover, there is concern that these code reviews
may not adequately inspect how voting system software interacts with
key election data.[Footnote 66] Specifically, security experts say that
a testing authority's source code review should include checks for
unique elements of the election contest, including (1) software modules
with inappropriate access to vote totals, ballot definition files, or
individual ballots; (2) functionality with time or date dependent
behavior; and (3) software modules that retain information from
previous screen touches or previous voters--all potentially indicative
of improper and malicious voting system behavior.[Footnote 67]
* As for penetration testing, experts expressed concerns that voting
system testing does not include such explicit security tests.[Footnote
68] An official from an independent testing authority generally agreed
and said that the security-related parts of their testing use a
checklist approach, based on what is called for in the voluntary voting
system standards. This official recommended more rigorous security
testing. Another testing authority official said that their testing
does not guarantee that voting systems are secure and reliable. This
official has called for local jurisdictions to conduct additional
security testing and risk analyses of their own.[Footnote 69]
Lack of transparency in the testing process. Security experts and some
elections officials have raised concerns about a lack of transparency
in the testing process. They note that the test plans used by the
independent testing authorities, along with the test results, are
treated as protected trade secrets and thus cannot be released to the
public.[Footnote 70] (Designated election officials may, in fact,
obtain copies of test results for their systems, but only with the
permission of the vendor.) As a result, critics argue, the rigor of the
testing process is largely unknown. Critics say that this lack of
transparency hinders oversight and auditing of the testing
process.[Footnote 71] This in turn makes it harder to determine the
actual capabilities, potential vulnerabilities, and performance
problems of a given system. Despite assertions by election officials
and vendors that disclosing too much information about an electronic
voting system could pose a security risk,[Footnote 72] one security
expert noted that a system should be secure enough to resist even a
knowledgeable attacker.[Footnote 73]
Security Management:
Numerous studies raised concerns about the security management
practices of state and local governments in ensuring the security of
electronic voting systems, citing poor version control of system
software and inadequate security management programs.
Poor version control of system software. Security experts and selected
election officials are concerned about the configuration management
practices of state and local jurisdictions. Specifically, the voting
system software installed at the local level may not be the same as
what was qualified and certified at the national or state
levels.[Footnote 74] These groups raised the possibility that either
intentionally or by accident, voting system software could be altered
or substituted, or that vendors or local officials might (knowingly or
not) install untested or uncertified versions of voting
systems.[Footnote 75] As a result, potentially unreliable or malicious
software might be used in elections. For example, in separate instances
in California and Indiana, state officials found that two different
vendors had violated regulations and state law by installing
uncertified software on voting systems.[Footnote 76]
Inadequate security management programs. Several of the technical
reviews mentioned previously also found that states did not have
effective information security management plans in place to oversee
their electronic voting systems.[Footnote 77] The reports noted that
key managerial functions were not in place, including (1) providing
appropriate security training, (2) ensuring that employees and
contractors had proper certifications, (3) ensuring that security roles
were well defined and staffed, and (4) ensuring that pertinent
officials correctly configure their voting system audit logs and
require them to be reviewed.
In addition, several reports indicated that some state and local
jurisdictions did not always have procedures in place to address
problems with their electronic voting systems.[Footnote 78] For
instance, one county in Pennsylvania reported that neither its election
staff nor its technical division knew how to deal with several problems
that occurred on election day.[Footnote 79] The report also cited (1) a
lack of preparation and contingency planning for significant problems,
(2) inadequate communication means between precincts and the county
election office for problem reporting, and (3) the absence of paper
ballots held in reserve as a backup. In addition, this and other
reports indicated that poll workers might not receive sufficient
training, or possess adequate technical skills or knowledge of their
particular systems to manage, administer, and troubleshoot
them.[Footnote 80]
While the concerns listed above are numerous, it is important to note
that many involved problems with specific voting system makes and
models or with circumstances in a specific jurisdiction's election.
Further, there is a lack of consensus among election officials,
computer security experts, and others on the pervasiveness of the
concerns. On one hand, both vendors and election officials express
confidence in the security of their current products. Election
officials note that their administrative procedures can compensate for
inherent system weaknesses, and they point out that there has never
been a proven case of fraud involving tampering with electronic voting
systems. Alternatively, citizen groups and computer security experts
note that administrative procedures cannot compensate for all of the
weaknesses and that if electronic voting system security weaknesses are
exploited, particularly by those with insider access to the systems,
changes to election results could go undetected.[Footnote 81]
Nevertheless, there is evidence that some of these concerns--including
weak controls and inadequate testing--have caused problems with recent
elections, resulting in the loss and miscount of votes. In light of the
recently demonstrated voting system problems, the differing views on
how widespread these problems are, and the complexity of assuring the
accuracy, integrity, confidentiality, and availability of voting
systems throughout their life cycles, the security and reliability
concerns raised in recent reports merit attention.
Recommended Practices Address Electronic Voting Systems' Security and
Reliability:
Several federal, academic, and nongovernmental organizations have
issued guidance to help state and local election officials improve the
election and voting processes. This guidance includes recommended
practices for enhancing the security and reliability of voting systems.
For example, in mid-2004, EAC issued a compendium of practices
recommended by elections experts, including state and local
jurisdictions.[Footnote 82] This compendium, among many suggested
practices, includes activities to help ensure a secure and reliable
voting process throughout a voting systems' life cycle. As another
example, in July 2004, the California Institute of Technology and the
Massachusetts Institute of Technology issued a report recommending
immediate steps to avoid lost votes in the 2004 election, including
suggestions for testing equipment, retaining audit logs, and physically
securing voting systems.[Footnote 83]
In addition to this election-specific guidance, the federal government
and other entities have published extensive guidance intended to help
organizations address, evaluate, and manage the security and
reliability of their information technology systems. This guidance
includes practices in the product development phase of the system life
cycle that may assist voting system vendors in adopting appropriate
standards and practices for designing and developing secure and
reliable voting systems. In addition, this guidance includes practices
in the areas of acquisition, testing, operation, and management that
may help state governments and local election officials in acquiring
technologies and services; assessing security risks; selecting,
applying, and monitoring security controls; auditing systems; and
adopting security policies.
The following is a high-level summary of common practices identified in
both general and election-specific reports that address the security
and reliability of electronic voting systems in the context of the
system life cycle phases and cross-cutting activities. The recommended
practices in both election-specific and IT-focused guidance documents
provide valuable guidance throughout a voting system's life cycle that,
if implemented effectively, should help improve the security and
reliability of voting systems. Appendix II provides a more detailed
summary of the election-specific publications' guidance on voting
system security and reliability practices, and appendix III provides
summaries of general guidance on information systems security.
Product Development:
* Voting system developers should define security requirements and
specifications early in the design and development process.
* The security requirements for voting systems should consider the
unique security needs of elections and the voting environment, as well
as applicable laws, national standards, and other external influences
and constraints that govern systems.
* Voting systems should contain audit logs that record all activity
involving access to and modifications of the system, particularly of
sensitive or critical files or data, including the time of the event,
the type of event and its result, and the user identification
associated with the event.
* Voting systems should employ adequate logical access controls over
software and data files. Systems should require that passwords be
changed periodically, and that they not use names or words from the
dictionary. Further, the use of vendor-supplied or generic passwords
should be prohibited.
* Vendors should review lessons learned from recent elections and
implement relevant mitigation steps to address known security
weaknesses (see app. II, table 16).
Acquisition:
* Election officials should focus on the security issues related to
electronic voting equipment before purchasing or implementing voting
systems.
* Requests for proposals should include security requirements and
evaluation and test procedures.
* Election officials should review lessons learned from recent
elections and implement relevant mitigation steps to address known
security weaknesses (see app. II, table 16).
Operations:
* State and local authorities should ensure that sensitive activities
in the election process, such as vote tabulation and the transporting
of ballots or election results, are performed by more than one person
or observed by representatives of both major parties.
* Procedures should be developed and followed to identify and document
the chain of custody for every instance when sensitive election items
(such as memory cards, ballots, and voting machines) change hands.
* Voting machines, ballots, memory cartridges, election supplies, and
offices should be physically secured against unauthorized access
before, during, and after an election.
* A postelection audit of voting systems should be conducted to
reconcile vote totals and ballot counts, even if there is no recount
scheduled.
* An audit of the election system and process should be conducted after
election day to verify that the election was conducted correctly and to
uncover any evidence of security breaches or other problems that may
not have surfaced on election day.
Standards:
* States should adopt the most current version of the national
voluntary voting standards or guidelines.
Testing:
* During the product development phase, electronic voting system
developers should verify and validate the security controls on the
system before deployment in order to ensure that the controls are
working properly and effectively and that they meet the operational
security needs of the purchasing jurisdiction.
* During the acquisition phase, states and local governments should
require that voting systems be certified against federal standards.
* During the operations phase, localities should conduct logic and
accuracy testing on voting machines before the election to ensure that
they accurately record votes.
Management:
* Voting system developers should establish a sound security policy
that identifies the security goals of their system; the procedures,
standards, and controls needed to support the system security goals;
the critical assets; and the security-related roles and
responsibilities.
* Voting system developers should conduct appropriate background
screening on all employees before granting them access to sensitive
information or placing them into sensitive positions.
* Election officials should plan for poll worker training early in the
process and ensure that all training classes and materials include
information on the security of voting systems and on election security
procedures.
* Election officials, not vendors, should control the administration
and use of the voting equipment. To that end, the election
administration team should include persons with expertise in both
computer security and voting system oversight.
* Election officials should conduct a risk analysis of voting systems
and address any identified vulnerabilities and points of failure in the
election process.
* Election officials should ensure that vendors provide tested and
certified versions of voting system software by requiring that software
be submitted to NIST's National Software Reference Library, and by
verifying that the systems, including hardware, software, and software
patches, have met all required standards through required
testing.[Footnote 84]
* Procedures and plans should be established for handling election day
equipment failure, including backup and contingency plans. If voting
machines malfunction during voting, they should not be repaired or
removed from the polling place on election day.
National Initiatives Are Under Way to Improve Voting System Security
and Reliability, but Key Activities Need to Be Completed:
Since the implementation of HAVA in 2002, the federal government has
begun a range of actions that are expected to improve the security and
reliability of electronic voting systems. EAC, with the support of TGDC
and NIST, is in the process of updating voluntary voting system
standards, is establishing federal processes to accredit independent
test laboratories and certify voting systems to national standards, and
is supporting state and local election management by providing a
library for certified software and acting as a clearinghouse for
information on voting system problems and recommended election
administration and management practices. However, a majority of these
efforts either lack specific plans for implementation in time to affect
the 2006 general election or are not expected to be completed until
after the 2006 election. As a result, it is unclear when these
initiatives will be available to assist state and local election
officials. In addition to the federal government's activities,
nongovernmental initiatives are under way to (1) define international
voting system standards; (2) develop designs for open voting system
products; (3) provide a framework of acquisition questions to use in
acquiring voting systems; and (4) support management of voting systems
by collecting and analyzing problem reports.
Federal Initiatives to Improve Voting Systems Security and Reliability
Are Under Way:
EAC, in collaboration with NIST and TGDC, has initiated efforts on
several of its key responsibilities relating to the security and
reliability of electronic voting systems, including improving voting
system standards, developing a process to facilitate testing systems
against the standards, and supporting state and local governments'
election management. Table 2 summarizes federal initiatives--both those
required by HAVA and those initiated by EAC to support HAVA
requirements.
Table 2: Federal Initiatives Related to Improving the Security and
Reliability of Voting Systems:
Standards:
Initiative: Draft initial set of voluntary voting system guidelines
(HAVA);
Responsibility: TGDC;
Status: Completed;
Actual or planned completion date: May 2005 (actual).
Initiative: Adopt voluntary guidance for certain voting system
standards (HAVA);
Responsibility: EAC;
Status: In process;
Actual or planned completion date: Fall 2005.
Initiative: Complete security and reliability updates to voting system
guidelines;
Responsibility: TGDC recommends; EAC approves;
Status: In process;
Actual or planned completion date: Not determined.
Testing:
Initiative: Conduct evaluation of independent testing laboratories for
accreditation (HAVA);
Responsibility: NIST;
Status: Not yet initiated;
Actual or planned completion date: By early 2007.
Initiative: Accredit first cadre of independent voting system testing
laboratories (HAVA);
Responsibility: NIST recommends; EAC approves;
Status: Not yet initiated;
Actual or planned completion date: By early 2007.
Initiative: Define interim process for certification of voting systems;
Responsibility: EAC;
Status: In process;
Actual or planned completion date: Fall 2005.
Initiative: Establish national program for voting system certification
(HAVA);
Responsibility: EAC;
Status: In process;
Actual or planned completion date: Not determined.
Management support:
Initiative: Establish national reference library for certified voting
system software;
Responsibility: NIST;
Status: Completed;
Actual or planned completion date: July 2004 (actual).
Initiative: Establish procedures for sharing problems associated with
voting systems;
Responsibility: NIST recommends; EAC approves;
Status: In process;
Actual or planned completion date: Not determined.
Initiative: Provide an initial report that includes best practices for
secure and reliable voting systems;
Responsibility: EAC;
Status: Completed;
Actual or planned completion date: August 2004 (actual).
Initiative: Provide periodic reports on election administration
practices (HAVA);
Responsibility: EAC;
Status: In process;
Actual or planned completion date: First report by December 2006; later
reports not determined.
Source: GAO analysis of HAVA and EAC, NIST, and TGDC data.
Note: Initiatives followed by (HAVA) are required by the Help America
Vote Act.
[End of table]
Standards. TGDC and NIST have been working on behalf of EAC to improve
the 2002 Federal Election Commission voluntary voting system
standards[Footnote 85] and their impact on the acquisition, testing,
operations, and management processes of the voting system life
cycle.[Footnote 86] TGDC approved 41 resolutions between July 2004 and
April 2005, many of which directed NIST to research and develop
recommendations for changing various voting system capabilities and
assurance processes. Of the 41 resolutions, 24 relate to the security
and reliability of voting systems. Appendix IV contains the relevant
resolutions and their status.
TGDC's initial priorities have been to correct errors and fill gaps in
the 2002 standards and to supplement them with provisions that address
HAVA requirements. In May 2005, TGDC approved a first set of
recommended changes and delivered them to EAC. Subsequently, EAC
published these changes as proposed voluntary voting system guidelines
and requested public comment by September 30, 2005. EAC plans to review
and address the comments it receives from the public and its standards
and advisory boards during October 2005, and to issue the 2005
Voluntary Voting System Guidelines shortly thereafter, depending on the
nature and volume of comments. EAC is proposing that the 2005 voluntary
voting system guidelines will become effective 24 months after they are
adopted by the EAC, although individual states will be free to adopt
the standards at any time during the 24 month period. According to the
EAC, the 24 month period is intended to give vendors the time to design
and develop systems that comply with the new guidelines; to give
testing laboratories the opportunity to develop testing protocols,
train laboratory staff, and be prepared to test the systems against the
new guidelines; and to allow states time to adopt the standards, adjust
their certification and acceptance testing processes, and acquire
systems in plenty of time for future election cycles.
Key security and reliability standards of the proposed 2005 guidelines
include:
* a method for distributing voting system software,
* protocols for generating and distributing software reference data for
the NIST repository of certified voting system software,
* a method for validating the proper setup of voting systems,
* controls for the use of wireless communications by voting systems,
and:
* optional specifications for a voter-verified paper audit trail.
However, NIST reported that several of the topics listed in the
proposed guidelines (including software distribution, validation of
system setup, and wireless communications) will not be fully addressed
in the 2005 update, and will need to be updated in a future version of
the guidelines. Furthermore, key security and reliability improvements
to the existing standards (including guidance for the security of COTS
software; ensuring the correctness of software, testing, and
documentation for system security; enhancements to the precision and
testability of the standards; and the usability of error messages) have
been deferred until the subsequent set of guidelines is developed. EAC
officials acknowledged that these changes will not be made in the
initial set of guidelines, and reiterated that they are focusing on
what can be done in time to meet the HAVA-mandated delivery date for
the initial set of guidelines.
Testing. EAC and NIST have initiatives under way to improve voting
system testing, including efforts to evaluate and accredit independent
testing laboratories (which test voting systems against the national
standards) and efforts to define both an interim process and a long-
term program for voting system certification.
* NIST is in the process of establishing plans and procedures to
conduct an evaluation of independent, nonfederal laboratories through
its National Voluntary Laboratory Accreditation Program. NIST solicited
feedback from interested laboratories concerning its accreditation
program, drafted a handbook that documents the accreditation process,
and accepted applications from its first cadre of candidate
laboratories through August 2005. The evaluation of candidate
laboratories is planned to begin in fall 2005. Once this evaluation is
completed, NIST plans to submit for EAC accreditation a proposed list
of laboratories to carry out the testing of voting systems. In light of
the time required to publicize the accreditation process and
requirements and to evaluate the first set of candidates, NIST
officials estimated that they would recommend laboratories for
accreditation in late 2006 or early 2007. Laboratories that are
currently accredited by the National Association of State Election
Directors can continue to operate as independent testing authorities
until June 2008, but are expected to complete NIST's new accreditation
program by that time. In addition, EAC officials stated that they are
in the process of developing plans and procedures with NIST and the
independent testing authorities to upgrade existing accreditations to
address the 2005 voting system standards, when these standards are
approved.
* EAC is working to establish a program to certify, decertify, and
recertify voting systems. With the assistance of a consulting firm, EAC
is in the process of defining certification policies and procedures,
both for systems undergoing testing with existing federal voluntary
voting system standards and for those that will be tested against EAC's
voluntary voting system guidelines. EAC officials expect to define the
scope and framework for the certification process and to begin to
accept vendor registrations during fall 2005. It also expects to begin
accepting applications for certification of voting systems by January
2006. EAC has not yet determined when it will have a national program
for voting system certification in place.
Management support. To address its responsibilities related to
providing election management support to state and local jurisdictions,
EAC and NIST have been working to establish a software library and to
act as a clearinghouse for information on both problems and recommended
practices involving elections and systems.
* In anticipation of the 2004 elections, EAC and NIST established a
software library for voting systems within NIST's National Software
Reference Library that allows state and local governments to verify
that their voting system software is the certified version (based on
testing by independent testing laboratories) and to manage the
configuration of that software for their systems. The library was
established before the 2004 general election with software from
approximately a half dozen major voting system vendors. NIST derived
digital signatures for the software and published them on the library's
public Web site for states and local jurisdictions to compare with the
signatures of software used by their systems.
* In January 2005, TGDC requested that NIST define a process and
specification for sharing information among jurisdictions regarding
nonconformities, problems, and vulnerabilities in voting systems, to
specifically address the security and reliability of those systems.
Such information could be used to alert state and local election
officials to known problems with their systems and to develop
additional recommended practices for their use. TGDC designated this
task as a third-tier priority and has deferred working on it until
after the publication of the 2005 voting system standards. In addition,
EAC surveyed state and local election officials to identify problems
they encountered during the 2004 election. However, election officials
often interpreted the survey questions differently, so not all of the
information resulting from this survey was complete or usable. EAC
plans to enhance its survey activities in the future.
* EAC is charged by HAVA with conducting periodic studies of election
administration issues with the goal of providing the most accurate,
secure, and expeditious system for voting and tabulating election
results.[Footnote 87] Toward this end, EAC compiled the experiences of
a select group of elections experts into a tool kit to help states and
local jurisdictions prepare for the 2004 general election.[Footnote 88]
It was published on EAC's Web site in August 2004 and publicized to
state and local jurisdictions before the election. The tool kit
provides recommendations for methods to manage and operate voting
systems to help ensure accurate and secure election results and
includes general practices for all voting systems and environments, as
well as controls for specific types of voting equipment. Since
developing the tool kit, EAC has included additional best practices
proposed by TGDC and NIST in the appendixes of its draft voting system
guidelines. These practices recommend that election officials establish
procedures for their jurisdictions to ensure, among other things, that
voting systems are physically secured against tampering and intentional
damage, cryptographic keys for wireless encryption are actively
managed, actions taken when using wireless communication are logged,
and the authenticity of certified software is confirmed using the
National Software Reference Library. EAC plans to update the practices
in the voting system guidelines and to compile a broader framework of
guidance for election administration and management practices that
incorporates the best practices tool kit and further promotes security
and reliability for voting systems. EAC has begun working with the
National Association of State Elections Directors to establish a
working group to develop additional guidelines and procedures for
election management and operations and has identified the personnel who
will support this effort. This fall, EAC expects the working group to
develop a comprehensive outline for the election management guidelines
document and to prioritize the topics to be developed for the initial
version scheduled to be released in December 2006. A final report is
expected in December 2007.
Tasks and Time Frames for Completing Federal Initiatives Are Not Fully
Defined:
While EAC has begun several important initiatives to improve the
security and reliability of voting systems, more remains to be done on
these initiatives, and specific tasks and time frames for performing
them are not fully defined.
Standards. EAC recognizes that its planned 2005 update to the standards
does not fully address known weaknesses. EAC and NIST are developing an
outline for the next iteration of the guidelines, but no date has been
set for NIST to deliver the next guidelines draft to TGDC. This rewrite
is expected to extensively change the existing standards and include,
among other features, quality management for system development, more
testable standards, and specifications for ballot formats. However,
neither TGDC nor NIST has defined specific tasks, measurable outcomes,
milestones, or resource needs for addressing the next draft of
standards. Consequently, the time frame for states and local
jurisdictions to implement the security and reliability improvements
associated with the next version of the standards is unknown. The
undefined time frame for completing the standards is likely to cause
concern for states required to comply with the federal standards by
statute, administrative rule, or condition of HAVA payments, and will
further delay the adoption of widely acknowledged capabilities needed
for secure and reliable systems.
Voting system certification. While EAC is working to define the scope
of a system certification process, much remains to be done before such
a process is put in place. Specifically, EAC still needs to establish
policies, criteria, and procedures to govern certification reviews and
decisions for existing standards, as well as the proposed 2005
standards. However, the specific steps and time frames for EAC to
execute each stage of its certification responsibilities have not yet
been decided. Until EAC establishes a comprehensive system
certification program, its processes may be inconsistent or
insufficiently rigorous to ensure that all certified systems meet
applicable standards.
Software library. NIST established a software reference library for
voting systems, but the usefulness of this library is questionable. The
initial set of voting system software deposited into the library was
not comprehensive, no additional voting system software has been
submitted to the reference library since the 2004 general election, and
neither EAC nor NIST has identified specific actions to encourage
participation from states, local jurisdictions, vendors, or independent
testing authorities for the 2006 federal election cycle. Additionally,
state and local jurisdictions require specialized tools and technical
support to verify that reference library software signatures match
those of their own software versions, but no consolidated and easily
accessible list of sources for these tools and services is currently
available to state and local jurisdictions. Further, NIST did not keep
statistics on the extent to which state and local jurisdictions used
the library during the 2004 election cycle to verify installation of
certified software by their vendors, and thus, it could not determine
whether its service was meeting state and local needs. Without the
continuous incorporation of certified software into the library and
processes that can be effectively implemented by state and local
governments, these entities are likely to face difficulty in ensuring
that their tested and operational voting systems are the same as those
that were certified. Further, without a mechanism for determining how
the library is being used and how it can be improved, the potential
benefits of the library may be greatly diminished.
Clearinghouse for information on problems and leading practices. To
fulfill its role as a clearinghouse for information on voting system
problems, EAC continues to explore issues of data collection for
problems with voting systems through enhancing its survey instrument to
collect problem information from election officials and working with
NIST to determine how to share this information. However, neither EAC
nor NIST has defined specific tasks or time lines for establishing
procedures for sharing problems or a repository for collecting them.
The continued absence of a national clearinghouse for voting system
problems means that segments of the election community may continue to
acquire and operate their systems without the benefit of critical
information learned by others regarding the security and reliability of
those systems. Regarding its efforts to develop broad guidance on
election administration practices, EAC has initial plans for moving
forward, but lacks a process and schedule for compiling and
disseminating this information on a regular basis. Until EAC puts such
a process in place, there is a risk that the guidance it provides may
become outdated and of little value to election officials.
Although EAC initiatives are expected to eventually provide more secure
and reliable systems and more rigorous and consistent quality assurance
processes for the states and jurisdictions that choose to use them,
how, when, and to what degree this will be accomplished is not clear.
Specific steps have not been identified to implement some of the
initiatives in time to affect the 2006 general election, and others are
not expected to be completed until after the 2006 election. This
situation is due, in part, to delays in the appointment of EAC
commissioners and in funding the commission. As a result, it is unclear
when the results of these initiatives will be available to assist state
and local election authorities.
Nongovernmental Initiatives Are Intended to Improve Voting System
Security and Reliability:
In addition to federal initiatives, initiatives by various
nongovernmental organizations nationwide have been established to
address the security and reliability of voting systems. Professional
organizations, academic institutions, and citizen advocacy groups have
initiatives that affect several areas of the voting system life cycle,
particularly product development, acquisition, standards, and
management. Selected initiatives include (1) developing open designs
for voting system products; (2) identifying issues and key questions to
be considered by consumers of electronic voting systems; (3) defining
international standards; and (4) supporting more effective management,
including collecting, cataloging, and analyzing problems experienced
during elections. Table 3 summarizes key initiatives.
Table 3: Nongovernmental Initiatives to Improve Voting System Security
and Reliability:
Product development:
Initiative: Prototype for an open-source electronic voting application;
Organization: Open Voting Consortium;
Product or activity: Developed a prototype for an open-source
electronic voting application that uses commercial hardware and
operating system components and provides (1) an electronic voting
machine that prints a paper ballot, (2) a ballot verification station
that scans the paper ballot and lets a voter hear the selections, and
(3) an application to tally the paper ballots;
Status: Continuing to add functionality to prototype. No specific
timetable.
Initiative: A Modular Voting Architecture;
Organization: Caltech/MIT Voting Technology Project;
Product or activity: Proposed an approach for building additional
security features into electronic voting systems through an alternative
voting system architecture;
Status: Completed August 2001. Available for implementation.
Acquisition:
Initiative: A Framework for Understanding Electronic Voting;
Organization: National Academy of Sciences' Computer Science and
Telecommunications Board;
Product or activity: Defining questions to help policy makers, election
officials, and the interested public understand the technology, social,
and operational issues relevant to electronic voting, including
security issues;
Status: Publication expected in fall 2005.
Initiative: Relative performance of voting system classes;
Organization: Brennan Center for Justice;
Product or activity: Started an independent assessment of electronic
voting system security and plans to develop a report describing the
relative performance of each class of voting systems;
Status: To be completed in fall 2005.
Standards:
Initiative: Project 1583 on Voting Equipment Standards;
Organization: Institute of Electrical and Electronics Engineers;
Product or activity: Developing a standard for voting equipment
requirements and evaluation methods, including security and reliability
characteristics;
Status: Project 1583 members in recess. No current plans to resume this
project's activities.
Initiative: Project 1622 on Voting Equipment Electronic Data
Interchange;
Organization: Institute of Electrical and Electronics Engineers;
Product or activity: Developing data formats to be used by voting
system components for exchange of electronic data, including data
related to secure and reliable system operations;
Status: Project 1622 officials are working to endorse a draft standard.
No specific timetable.
Initiative: Election Markup Language;
Organization: Organization for the Advancement of Structured
Information Standards;
Product or activity: Defined process and data requirements that include
security considerations for authentication, privacy/confidentiality,
and integrity;
Status: Officials are seeking approval for this markup language as an
international standard from the International Organization for
Standardization. No specific timetable.
Testing:
Initiative: Voting System Performance Rating;
Organization: Voting System Performance Rating;
Product or activity: Developing evaluation and performance assessment
tests for use in rating the performance of voting systems in subject
areas such as privacy, transparency, and ballot verifiability;
Status: Working groups are being organized and members plan to draft,
publish, and distribute a range of documents in each of the relevant
subject areas over the next 2 years.
Management:
Initiative: Professional Education Program;
Organization: The Election Center;
Product or activity: Created a professional education program designed
to provide training and certification to election officials and
vendors;
Status: Continuing to expand the curriculum. No specific timetable.
Initiative: Election Incident Reporting System;
Organization: Verified Voting;
Product or activity: Operating the Election Incident Reporting System,
a Web-based system to collect and disseminate information about local
voting systems and election irregularities;
Status: Plans to operate through future elections. No specific
timetable for supporting activities.
Initiative: Information clearinghouse;
Organization: VotersUnite!;
Product or activity: Operating a repository of news and events and a
newsletter service to share information among advocacy groups and
jurisdictions on a wide range of electronic voting problems and issues;
Status: Ongoing postings; Continuation uncertain due to limited
resources.
Initiative: A Center for Correct, Usable, Reliable, Auditable, and
Transparent Elections;
Organization: Johns Hopkins University;
Product or activity: Created a federally funded center that is to
conduct (1) research into the technological issues facing electronic
voting, (2) education efforts, aimed at higher education, focusing on
voting technology issues, and (3) outreach to stakeholders in the
election administration process, including vendors, election officials,
and community groups;
Status: Plans to conduct activities over 5 years.
Source: GAO summary of data provided by organizations listed above.
[End of table]
Conclusions:
Electronic voting systems hold promise for improving the efficiency,
accuracy, and accessibility of the elections process, and many are in
use across the country today. The American public needs to feel
confident using these systems--namely, that the systems are secure
enough and reliable enough to trust with their votes. However, this is
not always the case. Numerous recent studies and reports have
highlighted problems with the security and reliability of electronic
voting systems. While these reports often focused on problems with
specific systems or jurisdictions, the concerns they raise have the
potential to affect election outcomes. The numerous examples of systems
with poor security controls point to a situation in which vendors may
not be uniformly building security and reliability into their voting
systems, and election officials may not always rigorously ensure the
security and reliability of their systems when they acquire, test,
operate, and manage them.
These concerns have led to action. Multiple organizations have compiled
recommended practices for vendors and election officials to use to
improve the security and reliability of voting systems, and EAC has
initiated activities to improve voluntary voting system standards,
system testing programs, and management support to state and local
election authorities. However, important initiatives are unlikely to
affect the 2006 elections due, at least in part, to delays in the
appointment of EAC commissioners and in funding the commission.
Specifically, key security-related improvements to voting system
standards will not be completed in time, improvements to the national
system certification program are not yet in place, and efforts to
provide management support to state and local jurisdictions through a
software library and information sharing on problems and recommended
practices remain incomplete. Further, EAC has not consistently defined
plans, processes, and time frames for completing these activities, and
as a result, it is unclear when their results will be available to
assist state and local election officials. Until these efforts are
completed, there is a risk that many state and local jurisdictions will
rely on voting systems that were not developed, acquired, tested,
operated, or managed in accordance with rigorous security and
reliability standards--potentially affecting the reliability of future
elections and voter confidence in the accuracy of the vote count.
Recommendations for Executive Action:
To improve the potential for benefits to states and local election
jurisdictions, we recommend that the Election Assistance Commission
take the following five actions:
1. Collaborate with NIST and the Technical Guidelines Development
Committee to define specific tasks, measurable outcomes, milestones,
and resource needs required to improve the voting system standards that
affect security and reliability of voting systems.
2. Expeditiously establish documented policies, criteria, and
procedures for certifying voting systems that will be in effect until
the national laboratory accreditation program for voting systems
becomes fully operational, and define tasks and time frames for
achieving the full operational capability of the national voting system
certification program.
3. Improve management support to state and local election officials by
collaborating with NIST to establish a process for continuously
updating the National Software Reference Library for voting system
software; take effective action to promote use of the library by state
and local governments; identify and disseminate information on
resources to assist state and local governments with using the library;
and assess use of the library by states and local jurisdictions for the
purpose of improving library services.
4. Improve management support to state and local election officials by
collaborating with TGDC and NIST to develop a process and associated
time frames for sharing information on the problems and vulnerabilities
of voting systems.
5. Improve management support to state and local election officials by
establishing a process and schedule for periodically compiling and
disseminating recommended practices related to security and reliability
management throughout the system life cycle (including the recommended
practices identified in this report) and ensuring that this process
uses information on the problems and vulnerabilities of voting systems.
Agency Comments and Our Evaluation:
EAC and NIST provided written comments on a draft of this report (see
apps. V and VI). EAC commissioners agreed with our recommendations and
stated that actions on each are either under way or intended. NIST's
director agreed with the report's conclusions that specific tasks,
processes, and time frames must be established to improve the national
voting systems standards, testing capabilities, and management support
available to state and local election officials.
In addition to its comments on our recommendations, EAC commissioners
expressed three concerns with our use of reports produced by others to
identify issues with the security and reliability of electronic voting
systems. First, they noted that the draft lacked citations linking
security problems and vulnerabilities to the reports in the
bibliography and lacked context when referring to experts. We have
since provided citations and context, where applicable. Second,
commissioners expressed concern that the report portrays voting system
problems as systemic, but does not provide context for evaluating the
extent of the problems--that is, how frequently these issues arise or
whether the problems occur in a large percentage of electronic voting
systems or jurisdictions. We do not agree that we portray the problems
as systemic. Our report states that many of the issues involved
specific voting system makes and models or circumstances in the
elections of specific jurisdictions, and that there is a lack of
consensus on the pervasiveness of the concerns. This is due in part to
a lack of comprehensive information on what system makes and models are
used in jurisdictions throughout the country. Nonetheless, the numerous
examples of systems with poor security controls point to a situation in
which vendors may not be uniformly building security and reliability
into their voting systems, and election officials may not always
rigorously ensure the security and reliability of their systems when
they acquire, test, operate, and manage them. Third, commissioners
expressed concern that our report relies on reports produced by others
without substantiation of the claims made in those reports, and
provides specific examples that they felt should be verified with
election officials. While our methodology focused on identifying and
grouping problems and vulnerabilities identified in issued reports and
studies, where appropriate and feasible, we sought additional context,
clarification, and corroboration from the authors, election officials,
and security experts. In one of the specific examples offered by EAC,
we understand that the Florida demonstration may not have offered an
accurate assessment of the system's vulnerabilities to outsiders, but
it has value in identifying vulnerabilities to knowledgeable insiders.
In another example, EAC takes issue that we found no concerns with the
security and reliability during the acquisition phase of the voting
system life cycle and noted that they learned from state and local
officials that a number of voting equipment units have recently been
rejected during the acceptance testing phase of the acquisition process
demonstrating quality assurance or reliability concerns. We do not
question EAC's point, but this issue did not surface in the reports we
analyzed and the interviews we held--so we did not include it in our
report. This issue, however, shows that there could be security and
reliability issues that are not documented in existing reports.
Assessing security and reliability issues and determining their
pervasiveness are items that EAC can explore and share in its role as a
clearinghouse for information on problems with electronic voting
systems.
EAC commissioners also commented that our report focuses exclusively on
EAC as the answer to the questions surrounding electronic voting, and
stated that EAC is but one participant in the process of ensuring the
reliability and security of voting systems. They noted that while EAC,
TGDC, and NIST are working to develop a revised set of voting system
guidelines (standards), it is the voting system vendors that must
design and configure their systems to meet those guidelines and the
state and local election officials that must adopt the guidelines and
restrict their purchases of voting systems to ones that conform to the
guidelines. While we agree that EAC is one of many entities with
responsibilities for improving the security and reliability of voting
systems, given its leadership role in defining voting system standards,
in establishing programs both to accredit laboratories and to certify
voting systems, and in acting as a clearinghouse for improvement
efforts across the nation, we believe that our focus on EAC is
appropriate and addresses the objective of our requesters regarding the
actions that federal agencies have taken.
EAC and NIST officials also provided detailed technical corrections,
which we incorporated throughout the report as appropriate.
As agreed with your offices, unless you publicly announce the contents
of this report earlier, we plan no further distribution of it until 30
days from the report date. At that time, we will send copies of this
report to the Chairman and Ranking Member of the Committee on House
Administration and to the Chairman and Ranking Member of the Senate
Committee on Rules and Administration. We are also sending copies to
the Commissioners and Executive Director of the Election Assistance
Commission, the Secretary of Commerce, the Director of the National
Institute of Standards and Technology, and other interested parties. In
addition, the report will be available without charge on GAO's Web site
at [Hyperlink, http://www.gao.gov].
Should you have any questions about matters discussed in this report,
please contact Dave Powner at (202) 512-9286 or at [Hyperlink,
pownerd@gao.gov] or Randy Hite at (202) 512-3439 or at [Hyperlink,
hiter@gao.gov]. Contact points for our Offices of Congressional
Relations and Public Affairs can be found on the last page of this
report. GAO staff who made major contributions to this report are
listed in appendix VII.
Signed by:
David A. Powner:
Director, Information Technology Management Issues:
Signed by:
Randolph C. Hite:
Director, Information Technology Architecture and Systems Issues:
List of Congressional Requesters:
The Honorable Tom Davis:
Chairman:
The Honorable Henry A. Waxman:
Ranking Minority Member:
Committee on Government Reform:
House of Representatives:
The Honorable Jim Sensenbrenner, Jr.:
Chairman:
The Honorable John Conyers, Jr.:
Ranking Minority Member:
Committee on the Judiciary:
House of Representatives:
The Honorable Sherwood L. Boehlert:
Chairman:
The Honorable Bart Gordon:
Ranking Minority Member:
Committee on Science:
House of Representatives:
The Honorable William Lacy Clay:
House of Representatives:
The Honorable John B. Larson:
House of Representatives:
The Honorable Todd Platts:
House of Representatives:
The Honorable Adam Putnam:
House of Representatives:
The Honorable Ileana Ros-Lehtinen:
House of Representatives:
The Honorable Robert C. Scott:
House of Representatives:
The Honorable Christopher Shays:
House of Representatives:
The Honorable Michael Turner:
House of Representatives:
[End of section]
Appendixes:
Appendix I: Objectives, Scope, and Methodology:
Our objectives were to (1) determine significant security and
reliability concerns that have been identified for electronic voting
systems; (2) identify recommended practices relevant to the security
and reliability of such systems; and (3) describe the actions that
federal agencies and other organizations have taken, or plan to take,
to improve the security and reliability of electronic voting systems.
Our work focused on the security and reliability of optical scanning
and direct recording electronic voting systems, which includes
equipment for defining ballots, casting and counting ballots, managing
groups of interconnected electronic components, and transmitting voting
results and administrative information among the locations supporting
the voting process.
To determine significant security and reliability concerns and identify
recommended practices, we conducted a broad literature search for
existing published electronic voting studies. Our search included the
use of Internet sources, technical libraries, professional and
technical journals, and bibliographic information from articles and
documents we obtained. We also collected citations and contacts during
interviews with relevant officials and experts. To corroborate and
provide context for identified concerns and recommended practices, we
interviewed federal officials, election officials, computer and
information security experts, industry officials, and citizen advocacy
groups. Our interviews also included officials from nongovernmental
organizations involved with elections and electronic voting issues, as
well as members of our Executive Council on Information Management and
Technology. In addition, we examined testimony made before pertinent
federal bodies and other source material to provide supporting
information.
Through our literature search, we identified a number of reports that
addressed electronic voting issues. We organized these reports into
several content areas, including system security assessments,
reliability issues, general security issues, practices and
recommendations, and statistical analyses. To identify the most
relevant sources for our work, we then selected those reports that best
met selection criteria that we developed. The selection criteria
included the extent to which the report specifically addressed the
security and reliability of electronic voting systems and recommended
practices relevant to these systems; whether original data analysis was
conducted; author knowledge and experience; endorsements by pertinent
government organizations (which were often sponsors of reports); and
the authenticity of available copies of the report. We were interested
in targeting the more recent literature, but we included earlier
reports that were deemed particularly relevant to the objectives of our
work.[Footnote 89] To assist in our assessment of the reliability of
each report's findings, we also conducted reviews of a report's
methodology, including its limitations, data sources, and conclusions.
We also obtained permission to use and report on any documents that
were marked as confidential or otherwise sensitive.[Footnote 90] The
final lists of the selected literature we relied on for our work are
shown in the bibliography.[Footnote 91] Some reports were not selected.
For the most part, these reports did not directly focus on our work
objectives, and the selected reports presented a more thorough
treatment of the issues related to our work.
From the selected literature and corroborating interviews, we extracted
and summarized findings to create a list of security and reliability
concerns for electronic voting systems. We also identified and
summarized recommended practices for improving the security and
reliability of electronic voting systems. Additionally, we included
generally recommended practices issued by the federal government and
other organizations that promote security and reliability for
information systems engineering and management. We examined these
general practices to confirm their applicability to the voting
environment. However, our review of the recommended practices did not
include validating the quality or assessing the effectiveness of the
practices, or the extent to which the practices have been implemented
by states or local jurisdictions. Finally, using a systems life cycle
framework, we organized our list of concerns and recommended practices
according to the activities in the voting system life cycle model that
we developed.[Footnote 92]
To describe the actions that federal agencies and other organizations
have taken, or plan to take, to improve the security and reliability of
electronic voting systems, we reviewed the Help America Vote Act to
determine federal responsibilities and requirements for improving the
security and reliability of electronic voting systems. We attended
public meetings of the Election Assistance Commission, the National
Institute of Standards and Technology, and the Technical Guidelines
Development Committee; conducted interviews with officials from these
organizations and others; and obtained and analyzed supporting
documents, including the Voluntary Voting System Guidelines and the
resolutions of the Technical Guidelines Development Committee. We
evaluated the resolutions to identify those relevant to security and
reliability and identified the committee's priorities and plans for
implementing the resolutions. Additionally, we identified activities
being performed by nongovernmental organizations to improve the
security and reliability of electronic voting systems through a broad
literature search and interviews with electronic voting experts. These
organizations, including citizen advocacy groups as well as academic
and standards bodies, were selected based upon the degree to which
their initiative's goal addressed our objective (to improve the
security and reliability of electronic voting systems), the
demonstrated progress toward achieving the goal, the existence of plans
for specific products or activities, and willingness to discuss and
confirm each of these areas with us. We conducted interviews with
members of the nongovernmental organizations and analyzed supporting
documentation provided by them or available on their Web sites. We did
not evaluate the quality or effectiveness of these nongovernmental
initiatives.
We conducted our work at the Election Assistance Commission, the
National Institute of Standards and Technology, the National Academies
of Science, and several nongovernmental organizations in the
Washington, D.C., area. Our work was performed from January through
August 2005 in accordance with generally accepted government auditing
standards.
[End of section]
Appendix II: Selected Recommended Practices for Voting System Security
and Reliability:
Multiple organizations have issued collections of recommended practices
for establishing secure and reliable electronic voting systems. For
example, the Election Assistance Commission's Best Practices Tool Kit
is a central document for guidance on this topic. Developed under HAVA
for use by state and local election officials, this Web-based resource
presents guidance compiled from experienced representatives of the
election community, with links to Web-based references from a variety
of organizations where additional recommended practices are documented.
The tool kit references practices and studies from other organizations,
including the National Institute of Standards and Technology, the
Brennan Center for Justice at New York University, the Leadership
Conference on Civil Rights, the Caltech/MIT Voting Technology Project,
and the Election Center. Other organizations have also issued their own
sets of recommended practices. Many of the reports and studies that we
reviewed to identify concerns with electronic voting systems also
offered recommendations for mitigating the weaknesses they found. The
descriptions below summarize the aspects of this guidance pertaining to
the security and reliability of voting systems.
Election Assistance Commission: Best Practices Tool Kit. The Help
America Vote Act (HAVA) tasked the EAC with promoting, among other
things, accurate, convenient, and efficient methods of voting and
election administration in a variety of areas, including voting
technology, ballot design, and poll worker training. As part of its
efforts to address this requirement, EAC assembled a team of elections
officials for a 2-day working session in mid-2004 to create a "Best
Practices Tool Kit." The tool kit is a compendium of practices
recommended by elections experts, including state and local
jurisdictions. The immediate goal of the tool kit was to help local
election administrators in their management of the 2004 elections. The
practices and recommendations in the tool kit address the life cycle
activities of acquisition, operations, testing, and management. The
tool kit also includes practices that are specific to ensuring the
security and reliability of different types of electronic voting
systems in the areas of testing, operations, and management. Example
practices from the tool kit are provided in the following tables: table
4 identifies practices that pertain to all types of voting systems,
table 5 identifies practices that pertain to optical scan voting
systems, and table 6 identifies practices that pertain to direct
recording electronic (DRE) voting systems.
Table 4: EAC Security and Reliability Practices for All Types of Voting
Systems:
Life cycle activity: Acquisition;
Example practice:
* Develop a budget and procurement plan; make sure the procurement
process is open to public scrutiny and abides by state and county or
municipal guidelines;
* Before purchasing equipment or before implementation, you may find it
helpful to consult the National Institute of Standards and Technology
(NIST) analysis, "Recommended IT Security Product Life Cycle Product
Planning." The analysis provides a road map for planning, purchasing,
using, maintaining, and transitioning to electronic voting equipment,
with a particular focus on the security issues related to electronic
voting equipment.
Life cycle activity: Operations;
Example practice:
* Draft and implement well-organized procedures that identify the chain
of custody for every instance when the ballots and/or voting equipment
changes hands;
* Separate staff duties for each test you conduct, and require staff
signatures to ensure each procedure has been completed and
appropriately documented;
* If you must deliver election equipment or supplies to the polling
place before election day, seal equipment, supply boxes, and each
sensitive item in the box so you will know if tampering has occurred;
* Restrict access to election office both before and after election. At
the polling place, provide badges to poll workers and pollwatchers. At
your election headquarters, require staff and visitors to sign in, sign
out, and wear badges;
* Conduct a postelection audit of all electronic systems;
* Verify that the number of ballots cast matches the number of voters
who signed each precinct's roster;
* Develop administrative procedures (or implement those procedures
developed by state officials) to audit the accuracy of your election
results;
* If you are using a modem to transmit your unofficial results, use a
phone line--not a wireless connection--and ensure the modem encrypts
the information.
Life cycle activity: Testing;
Example practice:
* To reduce the risk of raising public concerns, conduct pre-testing
before conducting a public test to ensure that the machines are working
properly;
* Test every piece of voting equipment before deployment, using the
ballot styles for that election. Invite the public and media to a
public test of the system.
Life cycle activity: Management;
Example practice:
* Focus early on poll worker recruitment and training; poll workers
should practice each important component of the election process,
especially using the voting equipment;
* Include chain of custody instructions in poll worker training;
* Prepare back-up and emergency plans; conduct a risk analysis of the
election process and develop a plan for dealing with worst-case
scenarios;
* If introducing a new voting system, conduct voter and media outreach.
Develop brochures; set up self-help voting laboratories or kiosks at
city halls, libraries, etc; loan demonstration units to community
organizations; prepare materials for media outreach and conduct pre-
election briefings;
* Request that your vendor submits its certified software to the
National Software Reference Library (NSRL) at the National Institute of
Standards and Technology (NIST);
* Have your vendor supply you with a copy of its letter to NIST and the
state election office confirming receipt of the version of the software
that you are using;
* You may wish to contact NIST to inquire and to confirm that the
version of your vendor's software matches the certified version of the
software on file with NIST;
* Obtain documentation from your voting system vendor regarding the
national and/or state testing and certification that the system has
been through. Double check by contacting the state election office to
substantiate that your system as installed has been certified.
Source: GAO summary and categorization of EAC report.
[End of table]
Table 5: EAC Security and Reliability Practices for Optical Scan Voting
Systems:
Life cycle activity: Operations;
Example practice:
* Establish security procedures for printing and shipping of ballots;
* For in-precinct optical scan equipment, check to see that the
internal ballot box is empty at beginning of the day. Poll workers
should keep keys for machine and ballot box in a secure location;
* Have two poll workers transport results.
Life cycle activity: Testing;
Example practice:
* Test the calibration of every scanner before the election;
* Conduct printing tests and quality control tests.
Life cycle activity: Management;
Example practice:
* If using in-precinct counting system, provide poll workers with a
script for assisting the voter without compromising voter privacy;
* Provide poll worker training on ballot and equipment storage
requirements and security measures;
* Develop a troubleshooting plan. Define the response time--know how
long it will take to get a troubleshooter to the polling place;
* Establish procedures for handling a machine failure, such as roving
technicians, a technical help desk, and technical back-up support;
* Establish procedures for when security measures are not followed,
such as when materials come back unsealed or unsigned.
Source: GAO summary and categorization of EAC report.
[End of table]
Table 6: EAC Security and Reliability Practices for Direct Recording
Electronic Voting Systems:
Life cycle activity: Operations;
Example practice:
* Track overvotes and undervotes. Develop election day procedures to
help determine the nature and cause of undervotes and blank votes to
determine whether they are genuine undervotes or the result of voter
confusion;
* Require poll workers to keep a log of election day events and
problems, including voter complaints, that will help you to recreate
the events of the day;
* Keep a maintenance log for all voting system equipment. This log
should track who has had access to the machines;
* Develop chain of custody for memory cards and machines;
* Control access to the voter "smart cards.";
* Develop rules for access to any sensitive equipment;
* Check the machine's public vote counter to verify that the number of
voters who signed in matches the number of the public counter. Account
for any discrepancies.
Life cycle activity: Testing;
Example practice:
* Conduct, at a minimum, both acceptance testing and logic and accuracy
testing on each system. Logic and accuracy testing should include
"incremental testing";
* Conduct system diagnostics on every machine for every election before
you conduct logic and accuracy testing;
* Conduct postelection logic and accuracy testing of machines.
Life cycle activity: Management;
Example practice:
* Create a poll worker position that is dedicated to machine setup,
shutdown, and troubleshooting. Provide supplemental training on
equipment; supplement pay for extra training;
* Establish written procedures for handling election day equipment
failure;
* Conduct a risk analysis-- where are you most vulnerable to problems?
At what points are the system--both the administrative system and the
machines--most likely to break down? For example, is there an
indispensable person? If so, develop a plan for dealing with his/her
absence. Develop contingency plans, such as off-site storage of all
software and data;
* Ensure that all software, including patches, is certified.
Source: GAO summary and categorization of EAC report.
[End of table]
National Bureau of Standards: Accuracy, Integrity, and Security in
Computerized Vote-Tallying (NBS SP 500-158). In August 1988, the
National Bureau of Standards (the prior name for NIST) issued a report
authored by a well-known elections expert.[Footnote 93] The report is
referenced by EAC's tool kit. It makes recommendations regarding the
life cycle activities of product development, operations, testing, and
management that are intended for state and local elections officials.
The recommendations are largely related to implementation of
administrative controls and operational procedures, although the
recommendations related to system design are more specific. Example
recommendations from the report are given in table 7.
Table 7: NIST Security and Reliability Practices for Electronic Voting
Systems:
Life cycle activity: Product development;
Example practice:
* A computerized vote count should be able to be reproduced on a
recount with no more than a change in one vote for each ballot position
in ballot quantities of up to 100,000 when machine-generated ballots
are used;
* Each DRE machine should be designed so as to take a positive action
indicating a "no vote" for every choice that the voter fails to take.
Life cycle activity: Operations;
Example practice:
* It is strongly recommended that certified vote-tallying software not
be allowed to run on a multiprogrammed general-purpose computer on
which uncertified support software or applications also are being run;
* Access (i.e., security) controls must be in place during preparations
for voting, voting itself, and vote-tallying. These controls concern
access to sites, areas, facilities, equipment, documents, files, and
data;
* Application internal controls for DRE systems should be in place that
cover matching machine use with voter totals, vote reconciliations on
each machine, recounting of voter-choice sets, and postelection
checkout of machines.
Life cycle activity: Standards;
Example practice:
* Each state should consider the adoption of the Federal Election
Commission clearinghouse specifications.
Life cycle activity: Testing;
Example practice:
* All vote-tallying software, and all software used with it, should be
reviewed for integrity, that is, for the ability to carry out its
asserted function and to contain no hidden code;
* Vote-tallying software should be tested for logical correctness;
* DRE data entry hardware should be certified for logical correctness
by examination of the logic design and by testing under a large variety
of different conditions;
* Sufficient pre-election testing should be done so that errors in
software specialization or in implementation of logical rules, if any,
will become obvious.
Life cycle activity: Management;
Example practice:
* Expertise in internal control (which includes computer security)
should be added to the personnel complement in election administration
in order to assure implementation of applicable concepts.
Source: GAO summary and categorization of NIST report.
[End of table]
Brennan Center for Justice: Recommendations of the Brennan Center for
Justice and the Leadership Conference on Civil Rights for Improving
Reliability of Direct Recording Electronic Voting Systems. In 2004, the
Brennan Center for Justice at New York University and the Leadership
Conference on Civil Rights assembled a group of election and technology
experts to independently assess the security of DRE systems and to
develop recommendations for improving DRE reliability. The group issued
its recommendations in June 2004.[Footnote 94] The recommendations are
high-level policy recommendations and broad procedural statements
rather than low-level practices, and are focused primarily in the life
cycle area of management, with one recommendation each in the areas of
operations and testing. They were intended for use by elections
officials in jurisdictions planning to use DREs in the 2004 elections.
The EAC cited this report in its tool kit. Example practices from the
report are listed in table 8.
Table 8: Brennan Center Example Security and Reliability Practices for
Direct Recording Electronic Voting Systems:
Life cycle activity: Operations;
Example practice:
* Elections officials should establish standard procedures for regular
reviews of audit facilities and operating logs for voting terminals and
canvassing systems to verify correct operation and uncover any evidence
of potential security breaches.
Life cycle activity: Testing;
Example practice:
* Elections officials should develop procedures for random parallel
testing of the voting systems in use to detect malicious code or bugs
in the software.
Life cycle activity: Management;
Example practice:
* Elections officials should hire a well-qualified, independent
security team to examine the potential for operational failures of and
malicious attacks against the jurisdiction's DRE voting system;
* The assessment performed by the independent security team should
cover at least the following areas of concern: hardware design,
hardware/firmware configuration, software design, software
configuration, election procedures, and physical security;
* Election officials should implement the critical recommendations of
the independent expert security team and demonstrate to experts and
voters alike that the recommendations have been implemented;
* Election officials should provide a thorough training program for all
election officials and workers to ensure that security procedures,
including those recommended by the independent expert security team,
are followed even in the face of election day exigencies;
* All jurisdictions should prepare and follow standardized procedures
for response to alleged or actual security incidents that include
standardized reporting and publication;
* Election officials should have in place a permanent independent
technology panel, including both experts in voting systems and computer
security and citizens representing the diverse constituencies involved
in election oversight, to serve as a public monitor over the entire
process outlined above and to perform a postelection security and
performance assessment.
Source: GAO summary and categorization of Brennan Center report.
[End of table]
Election Center: Election Preparation Checklists. In May 2004, the
Election Center issued a series of five checklists designed to help
state and local election officials prepare for the November 2004
elections.[Footnote 95] The checklists include specific guidance in the
areas of polling place accessibility, security of paper ballots,
polling place preparations, voting systems, and procedures for
recounts. The EAC tool kit references the checklists as a group, and
specifically notes the accessibility and voting systems checklists.
Taken together, the checklists include recommendations in the life
cycle areas of operations, testing, and management. Example
recommendations are listed in table 9.
Table 9: Election Center Security and Reliability Practices for
Elections:
Life cycle activity: Operations;
Example practice: Ballot security:
* Are the polling place scanners/tabulators zeroed and sealed, and the
seal number recorded?
* Are the polling place scanners/tabulators and system software
prepared?
* Have you done a complete accounting to reconcile all numbers (so that
every ballot, used and unused, is accounted for)? Polling place
preparations:
* Have you prepared a list of duties (in time frame sequence) that need
to be accomplished in order to secure polling locations?
* Does the facility have sufficient electrical outlets? Voting systems:
* Have labels been printed for memory cards/tabulation chips, receipt
envelopes, machine tapes, envelopes, etc.?
* Have all peripheral voting supplies been packed, proofed, and
secured? Recount procedures:
* Keep an audit log of equipment programming, including the retention
of all nightly backups until after the deadline for recounts has
passed;
* Make certain all ballot containers are sealed, labeled, and accounted
for;
* Schedule recount. Establish complete calendar of events;
* Open sealed containers only when recount board and observers are
present;
* If manual count differs from the original results, you may want to
have a different recount team validate the results;
* Conduct every election as if it will be recounted. Public perception
is vital in conducting a recount. Providing information and forms in an
organized manner strengthens the perception of the overall integrity of
the process.
Life cycle activity: Testing;
Example practice: Ballot security:
* Has logic and accuracy testing been completed? Voting systems:
* Has logic and accuracy testing been scheduled?
* Has manual logic and accuracy testing been performed on every
tabulation chip/memory card in its election-specific machine? Recount
procedures:
* Keep an audit log of all equipment testing;
* Conduct the public test as published. Even if there are no observers,
it is important to be able to show that you performed a formal and
complete test of the system.
Life cycle activity: Management;
Example practice: Polling place preparations:
* Have you prepared a poll worker manual?
* Have you prepared training materials, including audio-visual
materials? Voting systems:
* Have pertinent federal laws that affect voting systems been
researched for an understanding of requirements?
* Have training materials for election workers been prepared and
printed?
* Have election workers been notified and assigned to training classes?
* Are you on the latest, tested, certified version of your voting
system software?
Source: GAO summary and categorization of Election Center report.
[End of table]
National Task Force on Election Reform: Election 2004: Review and
Recommendations by the Nation's Elections Administrators. In early
2005, the National Task Force on Election Reform within the Election
Center began to assemble its report on the 2004 election. The task
force was divided into three subcommittees in the areas of voter
registration, election technology, and redesigning elections; the
recommendations of each subcommittee were combined to produce the final
report and recommendations that were issued in May 2005.[Footnote 96]
The recommendations relevant to the security and reliability of
electronic voting systems are directed to NIST, the EAC, state
governments, and state and local election officials. They address the
life cycle activities of acquisition, standards, testing, and
management, with one recommendation in the area of operations. Examples
of the task force's recommendations relevant to the security and
reliability of voting systems are listed in table 10.
Table 10: National Task Force on Election Reform Security and
Reliability Practices for Voting Systems:
Life cycle activity: Acquisition;
Example practice: In the area of procurement of equipment, the task
force recommends:
* That the EAC develop and maintain a library of requests for proposals
(RFPs), contracts, and customer complaints as a resource for purchasing
jurisdictions;
* That states are encouraged to assist in procuring voting equipment
for local jurisdictions;
* That purchasing jurisdictions carefully and thoroughly document each
step of the procurement process;
* That the acquisition process require acceptance testing, independent
of the vendor, of all equipment and system components (hardware and
software) as part of the procurement and contract requirements.
Life cycle activity: Operations;
Example practice: In the area of Voter Verifiable Paper Audit Trail,
the task force recommends:
* That states develop procedures to safeguard and retain any paper
record receipt in the polling place to preserve secrecy of the voted
ballot.
Life cycle activity: Standards;
Example practice: In the area of procurement of equipment, the task
force recommends:
* That states adopt the voluntary voting system standards issued by the
Federal Election Commission and the voluntary voting system guidelines
issued by the U.S. Election Assistance Commission; In the area of Voter
Verifiable Paper Audit Trail, the task force recommends:
* That guidelines be developed by the National Institute of Standards
and Technology, through the EAC, for a scientifically sound,
independently verifiable audit trail for DRE voting systems and that
such guidelines not be restricted to contemporaneous paper replica but
also include guidelines for electronic, audio, video, or other media to
provide verification of the integrity of recording and tabulating
votes;
* That, for DRE voting systems, guidelines be developed by NIST,
through the EAC, for the contemporaneous recording of each ballot
record, on a secure medium, to provide a redundant record of votes.
Life cycle activity: Testing;
Example practice: In the area of logic and accuracy testing, the task
force recommends:
* That state and local election administrators develop and make
available to the public written documentation describing their logic
and accuracy testing procedures. These procedures should be
standardized throughout the state for each voting system;
* That the date and location of logic and accuracy testing be
publicized through media releases and public Web pages;
* That NIST provide testing standards and procedures by equipment type
for use by local and state election administrators in conducting logic
and accuracy testing;
* That local election administrators develop internal staffing
procedures to control, manage, and document the logic and accuracy
testing of their jurisdiction's voting equipment.
Life cycle activity: Management;
Example practice: In the area of poll worker recruitment and retention,
the task force recommends:
* That state and local jurisdictions implement supplemental training
and recognition programs for poll workers; In the area of procurement
of equipment, the task force recommends:
* That election officials develop clear, uniform, and nondiscriminatory
policies for determining the number of voting devices per polling site.
Source: GAO summary and categorization of National Task Force on
Election Reform report.
[End of table]
Caltech/MIT Voting Technology Project: Voting--What Is, What Could Be.
The Caltech/MIT Voting Technology Project issued its first report in
July 2001.[Footnote 97] Its recommendations are intended for all U.S.
officials with a role in the voting process. The report provides an
overview of the problems with election recounts and system failure that
were exposed during the 2000 presidential election controversy; makes
recommendations related to voting equipment, voter registration,
polling place operations, absentee and early voting, ballot security,
and the cost and financing of elections; and makes recommendations for
the future of the voting environment, such as proposing a new voting
system architecture, calling on the federal government to establish a
National Elections Research Laboratory, and calling for the greater
national collection and reporting of election administration data. The
recommendations in the report are primarily high-level policy proposals
and apply to each area of the voting system life cycle, including
product development, acquisition, operations, standards, testing, and
management activities. Some example recommendations from the report are
listed in table 11.
Table 11: Caltech/MIT Security and Reliability Practices for Voting
Systems:
Life cycle activity: Product development;
Example practice:
* Move away from complex, monolithic machines, to systems using a
simple electronic vote-recording device that is separate from other
parts of the system;
* Make source code for all vote recording and vote counting processes
open source and source code for the user interface proprietary;
* Design equipment that logs all events (votes, maintenance, etc.) that
occur on the machine.
Life cycle activity: Acquisition;
Example practice:
* Replace types of equipment that show high rates of uncounted,
unmarked, and spoiled ballots with optically scanned paper ballots that
are scanned at the polling place by the voter, or any electronic
technology proven in field tests.
Life cycle activity: Operations;
Example practice:
* Conduct audits of votes and equipment, even without a recount;
* Election administrators should measure the performance of individual
polling places in the areas of arrival process, authorization to vote,
voter education, and staffing practices and adopt management principles
to improve service.
Life cycle activity: Standards;
Example practice:
* The federal government should create and operate a National Election
Standards Commission to use historically proven methods to develop
standards;
* Within the existing standards framework: Include real voters in
testing process; Test equipment as it is set up and used at the polling
place; Require that all noninterface software be open source; Retest
systems after field use; Perform random system audits; Separate the
certification process for ease of use and for security.
Life cycle activity: Testing;
Example practice:
* The federal government should establish a program for field testing
all voting equipment and standard ballot formats.
Life cycle activity: Management;
Example practice:
* Train election officials in the interior workings of their voting
equipment.
Source: GAO summary and categorization of Caltech/MIT report.
[End of table]
Caltech/MIT Voting Technology Project: Immediate Steps to Avoid Lost
Votes in the 2004 Presidential Election. In July 2004, the Caltech/MIT
Voting Technology Project issued a report containing immediate
recommendations intended to help the EAC improve the election process
for 2004, along with additional recommendations that could have proven
more difficult to implement in time for the November 2004
election.[Footnote 98] While the recommendations were directed at the
EAC, many of them were specific enough to be used by state and local
election officials; the EAC referenced the report in its tool kit. The
report included security and reliability recommendations in the life
cycle areas of operations, testing, and management. Some example
recommendations from the report are listed in table 12.
Table 12: Caltech/MIT Security and Reliability Practices for Electronic
Voting Systems:
Life cycle activity: Operations;
Example practice:
* The EAC should require from each election jurisdiction (county and
state) a report of total ballots cast and votes cast for each federal
office;
* All election jurisdictions should also report on the voting
technologies they use for precinct and absentee voting in each federal
election;
* Audit logs of individuals with access to the computer must be
performed and retained after each election;
* Computers used for elections should be restricted to the sole purpose
of election administration, and not used for other purposes;
* Every stage of the election process should require that multiple
representatives approved by each major party be involved. The areas
that need such oversight include purchasing; equipment setup and
testing; ballot development; moving, storing, activating, using,
shutting down, and accumulating votes from voting equipment; setting up
polling places; testing and using registration and back-end software;
and designing and deploying education materials for poll workers and
election officials;
* Election machines (and ballots where ballots exist) should be well
secured. Ideally, numbered seals should be used as closures for the
equipment;
* In-precinct counting machines should not turn off the ballot overvote
and error checking features of these machines.
Life cycle activity: Testing;
Example practice:
* Every ballot design should be tested on real voters from the locality
where the ballot will be used. This testing must show the ballot to be
fully accessible and to allow voters to record their intentions
accurately;
* All voting machines should be tested and shown to work as designed
before use in any election. Machines should show zero counts; show that
all controls, indicators and displays work; show that they can
accurately record the votes made; and show that any back-up system in
them works. After any physical change or software rebuild, the voting
machine should be retested and recertified for use;
* A random sample of voting machines should be tested in voting mode as
though it were the day of the election.
Life cycle activity: Management;
Example practice:
* Poll workers should be trained with procedure-oriented teaching
materials and have ways of looking up answers to important questions in
a reasonable time;
* Election machines should be controlled by the election officials, not
the vendors. To do this, officials need to identify, train, and certify
representatives who are competent at overseeing voting machines;
* All software (including source code) for voting equipment should be
placed in escrow in case of questionable election outcomes and made
available for independent review.
Source: GAO summary and categorization of Caltech/MIT report.
[End of table]
League of Women Voters: Safeguarding the Vote. In July 2004 the League
of Women Voters produced a report[Footnote 99] containing
recommendations to local election officials that were intended to
advance security through, for example, enhanced transparency of the
elections and improved voting system testing and physical security. In
addition, this report provided advice specific to different types of
voting systems. The recommendations related to the security and
reliability of electronic voting systems fall in the life cycle
activities of operations, testing, and management. Example
recommendations from the report are listed in tables below. Table 13
provides examples relevant to all voting systems, table 14 provides
examples relevant to optical scan systems, and table 15 provides
examples relevant to DRE systems.
Table 13: League of Women Voters Security and Reliability Practices for
All Voting Systems:
Life cycle activity: Operations;
Example practice:
* Require bipartisan or third-party monitoring of sensitive election
procedures;
* Require tracking and documentation of all procedures from the testing
of machines to the handling of ballots;
* Restrict physical access to all components of voting systems;
* Ballots, voting machines, memory cartridges, and counting machines
should never be left unattended;
* Preferably two election officials will oversee all processes,
including the transfer of ballots and other election materials to the
central office;
* Design a routine process that checks for problems that may have
occurred but not been visible on election day; an audit of the election
after election day will provide the public with additional assurance
that all votes were counted properly and accurately, as well as alert
election officials to problems that occurred that may not have surfaced
on election day;
* Maintain and operate voting systems in isolation from networks and
the Internet.
Life cycle activity: Testing;
Example practice:
* Require that all systems, at a minimum, have been state certified and
meet all federal voluntary voting system standards;
* Test every voting machine to ensure it is operating properly;
* Perform uniform, public testing of voting systems;
* Test voting machines and counting machines, including their hardware
and software, before election day. Carry out testing in a public
process.
Life cycle activity: Management;
Example practice:
* Educate voters on the use of all voting equipment both in advance of
the election and in the polling place on election day;
* Establish statewide practices for the management and operation of
voting systems;
* Provide adequate training for all election day workers, including
ensuring the physical security of the voting system and other voting
system security vulnerabilities and countermeasures;
* Do not remove machines from the polls for repairs or for any other
reason until voting has ended;
* Provide a back-up plan in the event of machine failure;
* Establish statewide practices for the management and operation of
voting systems;
* Verify that the electronic and optical scan machines used are the
same as the systems that were certified.
Source: GAO summary and categorization of League of Women Voters
report.
[End of table]
Table 14: League of Women Voters Security and Reliability Practices for
Optical Scan Voting Systems:
Life cycle activity: Testing;
Example practices:
* Ensure that scanners are properly calibrated before election day.
Life cycle activity: Management;
Example practices:
* Both in-person and absentee voters should receive instructions on
what constitutes a spoiled ballot and what to do if they spoil their
ballot;
* Establish procedures for determining voter intent using uniform vote
counting standards and for counting ballots that cannot be scanned. The
process for counting ballots should be open and conducted under
bipartisan scrutiny.
Source: GAO summary and categorization of League of Women Voters
report.
[End of table]
Table 15: League of Women Voters Security and Reliability Practices for
Direct Recording Electronic Voting Systems:
Life cycle activity: Operations;
Example practices:
* On election day, periodically check to make sure machines are
properly calibrated and that cords remain plugged into their sockets;
* Configure the polling place to allow full view by poll workers of
voting and voter activity to guard against unauthorized access while
protecting voter privacy.
Life cycle activity: Testing;
Example practices:
* Test audio and magnification systems for each machine.
Source: GAO summary and categorization of League of Women Voters
report.
[End of table]
Numerous Reports Recommended Mitigation Steps. In addition to
highlighting problems and concerns, several of the reports we reviewed
identified specific measures designed to mitigate or otherwise address
the weaknesses in the security and reliability of electronic voting
systems. Some reports called on states and local governments to
implement both administrative and procedural safeguards to address
security and reliability on a comprehensive basis, as well as policies
to address specific weaknesses. In other cases, reports indicated that
vendors needed to redesign their systems in order to fix identified
technical deficiencies or physical security weaknesses in their
products. Table 16 lists mitigation measures identified in the reports
we reviewed.
Table 16: A Compendium of Recommended Mitigation Measures to Address
Selected Concerns with Electronic Voting Systems' Security and
Reliability:
Identified concern: Jurisdictions may lack an information security
management program for electronic voting systems;
Proposed mitigation measure: Develop and execute a security management
plan that includes provisions for;
* conducting appropriate security training;;
* ensuring that employees and contractors had proper certifications;;
* defining security roles and responsibilities;;
* performing audits according to a well-defined process;;
* managing passwords effectively, especially on systems with hard-coded
passwords or weak password controls;;
* controlling physical access to systems with weaknesses in their
system access controls; and;
* controlling the use of personal computer memory cards and smart cards
for systems that did not protect such devices.
Identified concern: Controls for protecting cast ballots, audit logs,
ballot definition files, and other vital data elements are weak;
Proposed mitigation measure:
* Redesign the voting system to provide encryption for these
components;
* Develop administrative procedures to tightly govern access to the
voting terminals, smart cards, and computers used to store accumulated
votes and other vital data.
Identified concern: System has network or modem connections that are
subject to external network attacks;
Proposed mitigation measure:
* When using network or modem connections, (1) encrypt transmissions,
(2) update with anti-virus protection, and (3) develop administrative
procedures to minimize the use of such connections.
Identified concern: Power or poll-closing switches are exposed and
vulnerable to accidental or intentional triggering;
Proposed mitigation measure:
* Apply a lockable protective seal to cover such buttons;
* Redesign the voting system to make such functionality password
protected.
Identified concern: The voting system may contain malicious code that
could corrupt votes;
Proposed mitigation measure:
* Redesign the system to include a voter-verified paper audit trail for
each vote cast.
Source: GAO analysis of recent reports and studies.
[End of table]
[End of section]
Appendix III: Summary of Selected Guidance on Information Technology
Security and Reliability:
The federal government and other entities have published broad guidance
intended to help organizations develop, evaluate, and manage
information technology systems in a secure and reliable manner. We have
identified examples of such guidance issued by ourselves and six other
organizations: National Institute of Studies and Technology (NIST), the
Information Systems Security Engineering Association, the Computer
Emergency Response Team (CERT) Coordination Center at the Software
Engineering Institute (SEI), the SysAdmin, Audit, Network, Security
(SANS) Institute, the Institute for Electrical and Electronics
Engineers (IEEE), and the American Institute of Aeronautics and
Astronautics (AIAA). These are summarized below. As technology
continues to evolve and these guidance documents are updated to address
emerging issues, stakeholders in voting systems must ensure that their
own standards and practices are upgraded to keep pace.
Federal Information System Controls Audit Manual (FISCAM).[Footnote
100] In January 1999, we issued guidance for reviewing information
system controls that affect the integrity, confidentiality, and
availability of computerized data. Designed for use by information
system auditors, FISCAM defines six major categories of general
controls: entitywide security program planning and management; access
controls; application software development and change controls; system
software; segregation of duties; and service continuity. For each
category, FISCAM identifies critical elements essential for
establishing adequate controls. State and local jurisdictions acquiring
new voting systems or evaluating controls associated with existing
systems may use the guidance from FISCAM to make purchasing decisions
or to set administrative policy or procedures.
GAO: Information Security Risk Assessment: Practices of Leading
Organizations. Our Information Security Risk Assessment guide[Footnote
101] is intended to help federal managers implement an ongoing
information security risk assessment process by providing case studies
containing examples of practical risk assessment procedures that have
been successfully adopted by organizations. It also identifies critical
success factors important to the success of a risk assessment program,
such as the involvement of senior management, defined procedures for
conducting the assessments, and documenting and maintaining the risk
assessment results.
NIST: Computer Security Special Publications. The NIST Computer
Security Division has published several guides promoting information
security development and management practices. These guides address
topics such as information security management, acquisition practices,
design and development principles, and operation of information
systems. Such guides could be used by vendors and developers for the
design and development of secure and reliable voting systems, as well
as by states and localities for acquisition practices and information
management principles. Examples of NIST publications that address
system security and reliability are listed in table 17.
Table 17: Examples of NIST Publications Addressing System Security and
Reliability:
NIST Publication: SP 800-12: An Introduction to Computer Security: The
NIST Handbook (October 1995);
Description: Explains important concepts, cost considerations, and
interrelationships of security controls. It is intended to help readers
understand their computer security needs and develop a sound approach
to the selection of appropriate management, operational, and technical
controls.
NIST Publication: SP 800-14: Generally Accepted Principles and
Practices for Securing Information Technology Systems (September 1996);
Description: Describes 8 principles and 14 related practices related to
information security. It is designed to serve as a foundation that
management, internal auditors, users, system developers, and security
practitioners can use to gain an understanding of the basic security
requirements most information technology systems should contain and to
establish and review information technology security programs.
NIST Publication: SP 800-18: Guide for Developing Security Plans for
Information Technology Systems (December 1998);
Description: Describes a guideline for federal agencies to follow when
developing the security plans that document the managerial, technical,
and operational controls for information systems. It provides guidance
on the general information that all security plans should contain as
well as the management, operational, and technical controls that should
be considered for both major applications and general support systems.
NIST Publication: SP 800-23: Guidelines to Federal Organizations on
Security Assurance and Acquisition/Use of Tested/Evaluated Products
(August 2000);
Description: Provides guidelines for federal organizations' acquisition
and use of security-related information technology products. It
recommends that agencies become aware of the benefits of testing
products against customer, government, or vendor-developed
specifications; consider the risk environment, cost-effectiveness,
assurance level, and security functional specifications when selecting
information technology products; procure and deploy products that have
been independently evaluated and tested against appropriate security
specifications, and configure and integrate technology products to
ensure that security is appropriately addressed throughout the system.
NIST Publication: Federal Information Technology Security Assessment
Framework (November 2000);
Description: Identifies five levels of information technology security
program effectiveness that measure specific management, operational,
and technical control objectives. It is intended to help agency
officials determine the current status of their security programs
relative to existing policy and to establish a target for improvement.
It may be used to assess the status of security controls for
information systems.
NIST Publication: SP 800-26: Security Self-Assessment Guide for
Information Technology Systems (November 2001);
Description: Provides guidance on applying the Federal Information
Technology Security Assessment Framework through a questionnaire
containing specific control objectives and suggested techniques against
which the security of information systems can be measured.
NIST Publication: SP 800-27, Rev. A: Engineering Principles for
Information Technology Security (A Baseline for Achieving Security)
(June 2004);
Description: Presents a list of 33 system-level security principles to
be considered in the design, development, and operation of information
systems. These principles are derived from the concepts defined in SP
800-14, Generally Accepted Principles and Practices for Securing
Information Technology Systems, and are intended to be used throughout
the system life cycle or to help organizations affirm the security
posture of already deployed systems. They primarily focus on technical
controls, but they also consider nontechnical issues in system security
design such as policy, operational procedures, and training.
NIST Publication: SP 800-30: Risk Management Guide for Information
Technology Systems (July 2002);
Description: Provides guidance to information technology personnel on
the development of an effective risk management program by providing
the definitions and the practical guidance necessary for assessing and
mitigating risks identified within information technology systems, and
by providing information on the selection of cost-effective security
controls. It describes a methodology, a process, and a practice needed
for conducting risk assessment, risk mitigation, and risk evaluation
and assessment.
NIST Publication: SP 800-34: Contingency Planning Guide for Information
Technology Systems (June 2002);
Description: Provides instructions, recommendations, and considerations
for government organizations to consider when developing a plan for
recovery of information technology services following an emergency or
system disruption. It contains specific contingency planning
recommendations for multiple information system platforms and provides
strategies and techniques common to all systems.
NIST Publication: SP 800-37: Guide for the Security Certification and
Accreditation of Federal Information Systems (May 2004);
Description: Provides guidelines for the security certification and
accreditation of information systems supporting the federal government.
It presents a four-phase process for security certification and
accreditation, with each phase containing specific tasks and subtasks,
which is intended to enable consistent assessments of system security
controls, promote understanding of risks resulting from the operation
of information systems, and facilitate more informed security
accreditation decisions by providing more complete information to
authorizing officials.
NIST Publication: SP 800-50: Building an Information Technology
Security Awareness and Training Program (October 2003);
Description: Provides guidelines for building and maintaining a
comprehensive awareness and training program, as part of an
organization's information technology security program. The guidance is
presented in a life cycle approach, ranging from designing, developing,
and implementing an awareness and training program, through
postimplementation evaluation of the program. It includes guidance on
how information technology security professionals can identify
awareness and training needs, develop a training plan, and get
organizational buy-in for the funding of awareness and training program
efforts.
NIST Publication: SP 800-53: Recommended Security Controls for Federal
Information Systems (February 2005);
Description: Provides guidelines for selecting and specifying security
controls for federal information systems. It describes a process for
selecting and specifying security controls for information systems,
catalogs specific security controls organized into management,
operational, and technical controls, and summarizes the minimum
controls needed for low-impact, moderate-impact, and high-impact
systems.
NIST Publication: SP 800-55: Security Metrics Guide for Information
Technology Systems (July 2003);
Description: Provides guidance for the specific development, selection,
and implementation of system-level metrics to be used to measure the
performance of information system security controls and techniques. It
describes the process for development of useful metrics and how to
implement a metrics program, as well as presenting a list of example
security metrics that can be used or modified to meet specific
organizational requirements.
NIST Publication: SP 800-61: Computer Security Incident Handling Guide
(January 2004);
Description: Assists organizations in establishing a computer security
incident response capability and handling incidents efficiently and
effectively. It also presents requirements and recommendations that
organizations should implement in order to facilitate effective
incident response and provides guidance in handling specific types of
incidents.
NIST Publication: SP 800-64, Revision 1: Security Considerations in the
Information System Development Life Cycle (June 2004);
Description: Presents a framework for incorporating security across the
life cycle of a system and describes a minimum set of security steps
needed to effectively incorporate security into a system during its
development. It is intended to help agencies select and acquire cost-
effective security controls by explaining how to include information
system security requirements in the system development life cycle.
NIST Publication: SP 800-70: Security Configuration Checklist Program
for IT Products--Guidance for Checklist Users and Developers (May
2005);
Description: Describes a program for facilitating the development and
sharing of security configuration checklists so that organizations and
individual users can better secure their information technology
products. It is intended to provide a framework for developers to
submit checklists to NIST; to assist developers by providing a
consistent approach to securing different types of systems that are
connected to the same environments; to assist developers and users by
providing guidelines for making checklists better documented and more
usable; to provide a managed process for the review, update, and
maintenance of checklists; and to provide an easy-to-use national
repository of checklists.
Source: NIST.
[End of table]
CERT/CC: Security Improvement Modules. The CERT Coordination Center
(CERT/CC) at the Software Engineering Institute at Carnegie Mellon
University provides a series of Security Improvement Modules and
associated practices[Footnote 102] intended to help system and network
administrators improve the security of their information systems and
networks. The modules contain practices and recommendations in such
areas as the outsourcing of security services, implementing system
security, detecting and responding to intrusions, and securing system
hardware.
International Systems Security Engineering Association: Systems
Security Engineering Capability Maturity Model (ISO/IEC 21827). The
International Systems Security Engineering Association promotes and
maintains the Systems Security Engineering Capability Maturity Model
(SSE-CMM)Ū. Version 3.0 of the SSE-CMM was issued in June 2003. The SSE-
CMM is a process reference model describing the requirements for
implementing security in information systems. It describes security
engineering activities for secure product definition, design,
development, and operation and requirements for developers, system
integrators, information security providers, and engineers. It
identifies a comprehensive framework with associated security
engineering activities designed to help provide a method by which
system developers can measure and improve performance in the
application of security engineering principles.
SANS Institute: Resources and Guidance. The SANS Institute, established
in 1989 as a cooperative research and education organization, provides
a variety of resources to help organizations implement and improve
system security. Its Web site[Footnote 103] provides guidance on
writing information security policies and offers templates for
organizations to use in developing their own policies. SANS also offers
the Information Security Reading Room,[Footnote 104] a collection of
research documents on various aspects of information security. The
documents address a variety of information security topics, such as
security basics, information assurance, wireless access, physical
security, and disaster recovery. They could be used by states and local
election administrators as a resource to set security policies or
create procedures for handling security and reliability problems. SANS
also offers a security awareness training program and publishes a list
of common security vulnerabilities.
IEEE Std 1332-1998: IEEE Standard Reliability Program for the
Development and Production of Electronic Systems and Equipment. This
standard is intended to encourage suppliers and customers to
cooperatively integrate their reliability processes and to establish a
contractual or obligatory relationship that promotes reliability
management. It is intended to help guide suppliers in developing a
reliability program that meets the needs of the customer through
meeting three objectives: determining the customer's requirements,
determining a process to satisfy those requirements, and verifying that
the customer's requirements and product needs are met. Further, it
describes activities that both the customer and the supplier should
perform to meet these objectives.
ANSI/AIAA R-013-1992: Recommended Practice for Software Reliability.
This recommended practice defines a methodology for software
reliability engineering. It describes activities and qualities of a
software reliability estimation and prediction program, presents a
framework for risk assessment and failure rate prediction, recommends
models for estimation and prediction of software reliability, and
specifies mandatory as well as recommended software reliability data
collection requirements. It is intended to support the design,
development, and testing of software, including activities related to
software quality and software reliability, as well as to serve as a
reference for research on the subject of software reliability.
[End of section]
Appendix IV: Resolutions Related to Voting System Security and
Reliability:
The Election Assistance Commission's (EAC) Technical Guidelines
Development Committee (TGDC) has approved 41 resolutions to improve
current voluntary voting system standards. Of the 41 resolutions, 24
have potential to improve the security and reliability of electronic
voting systems. Table 18 provides information on these 24 resolutions
including our determination of their relevance to security and
reliability goals, TGDC's priorities for resolutions related to the
development of voluntary voting system guidelines (VVSG), and the
version of guidelines that is expected to address each resolution. The
table shows that the majority of the 24 resolutions--including three
high-priority resolutions--are not expected to be fully addressed in
the 2005 update to the voting standards. Instead, most are expected to
be addressed in a future version.
Table 18: Resolutions Related to Security and Reliability of Electronic
Voting Systems and Plans for Implementing Them in Future Standards:
Resolution number: 05-04;
Date approved: 07/09/04;
Resolution title: Certified Software for the National Software
Reference Library;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: not prioritized;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Not expected to be addressed in publication.
Resolution number: 03-05;
Date approved: 01/19/05;
Resolution title: Human Factors and Privacy of Voting Systems at the
Polling Place;
Goal: Improve security: Resolution is not essential to the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 1,2;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 08-05;
Date approved: 01/19/05;
Resolution title: Usability Guidance for Instructions, Ballot Design,
and Error Messages;
Goal: Improve security: Resolution is not essential to the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 09-05;
Date approved: 01/19/05;
Resolution title: General Voting System Human Factors and Privacy
Considerations;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 1,2;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 12-05;
Date approved: 01/19/05;
Resolution title: Voter Verifiability I;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution is not essential to the goal;
TGDC priority: 1,2;
2005 VVSG: Expected to be partially addressed in publication, Supports
voter-verified paper audit trail implementation;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 14-05;
Date approved: 01/19/05;
Resolution title: Commercial Off-the-Shelf Software;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution is not essential to the goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 15-05;
Date approved: 01/19/05;
Resolution title: Software Distribution;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 1;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 16-05;
Date approved: 01/19/05;
Resolution title: Setup Validation;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 1;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 17-05;
Date approved: 01/19/05;
Resolution title: Testing (for Security);
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 18-05;
Date approved: 01/19/05;
Resolution title: Documentation (for Security);
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 21-05;
Date approved: 01/19/05;
Resolution title: Multiple Representations of Ballots;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution specifically identifies the goal;
TGDC priority: 2;
2005 VVSG: Expected to be partially addressed in publication; Supports
voter-verified paper audit trail implementation;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 22-05;
Date approved: 01/19/05;
Resolution title: Federal Standards;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution is not essential to the goal;
TGDC priority: 2;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 23-05;
Date approved: 01/19/05;
Resolution title: Common Ballot Format Specifications;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution is not essential to the goal;
TGDC priority: 3;
2005 VVSG: Expected to be partially addressed in publication; Supports
voter-verified paper audit trail implementation;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 24-05;
Date approved: 01/19/05;
Resolution title: Conformance Clause;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 1,2;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 25-05;
Date approved: 01/19/05;
Resolution title: Precise and Testable Requirements;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution specifically identifies the goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 26-05;
Date approved: 01/19/05;
Resolution title: Uniform Testing Methods and Procedures;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 27-05;
Date approved: 01/19/05;
Resolution title: Non-Conformant Voting Systems;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 29-05;
Date approved: 01/19/05;
Resolution title: Ensuring Correctness of Software Code;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 2;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 30-05;
Date approved: 01/19/05;
Resolution title: Quality Management Standards;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 3;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 32-05;
Date approved: 01/19/05;
Resolution title: Sharing Information and De-Qualification of Voting
Systems;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution specifically identifies the goal;
TGDC priority: 3;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Not expected to be addressed in publication.
Resolution number: 33-05;
Date approved: 01/19/05;
Resolution title: Glossary and Voting Model;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: 1,2;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 35-05;
Date approved: 01/19/05;
Resolution title: Wireless;
Goal: Improve security: Resolution specifically identifies the goal;
Goal: Improve reliability: Resolution is not essential to the goal;
TGDC priority: 1;
2005 VVSG: Expected to be partially addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 36-05;
Date approved: 03/09/05;
Resolution title: Consensus Standards;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: not prioritized;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Expected to be fully addressed in publication.
Resolution number: 39-05;
Date approved: 04/21/05;
Resolution title: Voter-Verified Paper Audit Trail Assignment;
Goal: Improve security: Resolution facilitates achievement of the goal;
Goal: Improve reliability: Resolution facilitates achievement of the
goal;
TGDC priority: not prioritized;
2005 VVSG: Not expected to be addressed in publication;
Future VVSG: Not expected to be addressed in publication.
Source: GAO analysis of NIST and TGDC data.
[End of table]
[End of section]
Appendix V: Comments from the Election Assistance Commission:
U.S. ELECTION ASSISTANCE COMMISSION:
1225 New York Ave. NW - Suite 1100:
Washington, DC 20005:
September 13, 2005:
Mr. David A. Powner, Director:
Information Technology Management Issues:
Mr. Randolph C. Hite, Director:
Information Technology Architecture and Systems:
United States Government Accountability Office:
RE: Draft Report GAO 05-956, Elections: Federal Efforts To Improve
Security and Reliability of Electronic Voting Systems are Under Way,
but Key Activities Need to be Completed:
Thank you for the opportunity to comment on draft GAO Report 05-956.
The EAC appreciates the time and effort put forth by GAO during the
preparation of this document and the willingness of GAO staff to
discuss pertinent issues at length with the EAC, NIST and other key
players in the election community. As you know this letter follows a
combined exit conference and discussion of GAO's draft report. Because
our meeting was scheduled late in the process, there may be some
comments set forth below that have already been addressed.
It is apparent from our review of the draft report that GAO has taken
steps in this engagement to understand the election process in addition
to evaluating the electronic voting systems in use in that process. EAC
is also pleased that GAO recognizes and highlights the decentralized
nature of the election process in the United States, the intricacies
this decentralization brings to our election system and the critical
roles played by local, state and Federal election officials in this
process.
While the overall quality of the report is quite high, the EAC does
have some issues we feel need to be addressed prior to the final
publication of this document. During our September 7, 2005 meeting, we
highlighted and provided to you a list of technical corrections to the
facts as stated in the draft report. For your convenience, a copy of
that list, as amended based upon the conversations in that meeting, has
been attached to this letter. (Appendix "1")
GENERAL COMMENTS:
GAO's draft report does not refer to sources.
Although the bibliography in Appendix V of the report lists numerous
studies on the security and reliability of electronic voting, few if
any, of these studies are cited or footnoted within the body of the
report. The report generally refers to "security experts and others"
without providing any specific reference to the individual sources or
the reports on which the statements that follow such generalities are
based. Including specific citations where appropriate would lend much
needed support to various broad statements and generalizations made
throughout the report regarding the lack of security and reliability of
electronic voting systems.
GAO's draft report does not give context to the identified security and
reliability issues.
GAO identifies several incidences of voting system security or
reliability problems. However, the report does not provide a context of
the pervasiveness or relative obscurity of these issues. There is no
statistical evidence offered as to how frequently these issues arise or
whether problems occur in a large or small percentage of electronic
voting system usage. While it has been offered by GAO that these
reported problems or issues systemic, the report fails to identify
whether the identified problems are voting system specific,
jurisdiction specific, or cross lines of both manufacturers and voting
jurisdictions.
GAO's draft report reflects significant reliance on reports produced by
others without substantiation of the claims made in those reports.
The LAC is concerned about instances of electronic voting system
failures highlighted in the report that do not appear to have been
thoroughly researched and analyzed. As an example page 26 or the report
states, in part, that:
".. computer security experts working with a local election supervisor
in Florida demonstrated that someone with access to an optical scan
voting system could falsify election results without leaving any record
of this action in the system's audit logs by using altered memory
cards. " This statement should be verified with election officials and
voting systems experts at the state level in Florida to assure its
accuracy, and to get a full understanding of the details and validity
of this so-called "demonstration."
In another example, on page 25 of the draft report, GAO relies on the
reports contained in its bibliography to state that there are no
significant concerns with security or reliability at the acquisition
phase of the voting system life cycle. Conversations with state and
local election officials that have recently purchased electronic voting
equipment would reveal that a significant number of voting systems are
rejected during the acceptance testing phase of acquisition. While this
may not point to a security concern, it does demonstrate a quality
assurance or reliability concern.
EAC is but one participant in the process of assuring reliability and
security of voting systems.
While GAO has done a good job with recognizing that the
decentralization of elections in this country --that is federal
elections as well as state elections are administered by state and
local election officials - the report fails to capture EAC's role in
the improvement to security and reliability of electronic voting
systems. EAC is the federal agency responsible for establishing a
uniform set of guidelines (testing standards) against which voting
systems can be measured. EAC, its advisory committee - the Technical
Guidelines Development Committee --, and the National Institute of
Standards and Technology are working diligently to develop a revised
set of voting system guidelines. However, the guidelines are only one
piece of the puzzle. It is the voting system vendors that must design
and configure their systems to meet those guidelines and the state and
local election officials that must adopt these guidelines and restrict
their purchases of voting systems to those that conform to the
guidelines. GAO's draft report focuses exclusively on EAC as the answer
to the questions surrounding electronic voting. In reality, EAC simply
cannot change the security and reliability of voting systems alone.
TECHNICAL COMMENTS:
At our meeting on September 7, 2005, EAC identified a number of
technical corrections related to specific facts or statements made in
the report. In addition to the items enumerated in writing, our
discussions produced several other technical errors that needed
correction. For your convenience, an updated list of technical comments
has been attached to this letter as Appendix "1".
RESPONSES TO GAO RECOMMNEDATIONS:
The EAC agrees with GAO that the implementation of the five
recommendations presented in this report will improve the voting
process and the public perception regarding the security and
reliability of electronic voting systems. Prior to the issuance of this
report and prior to EAC receiving a draft of this report, EAC took
significant steps toward accomplishing the very processes, procedures
and methods recommended by GAO. Provided below is additional
information concerning EAC's efforts relative to each of the five
recommendations.
Recommendation 1: Collaborate with NIST and the Technical Guidelines
Development Committee to define specific tasks, measurable outcomes,
milestones, and resource needs required to improve the voting system
standards that affect security and reliability of voting systems.
NIST and EAC have begun to define specific tasks and outcomes for
subsequent iterations of the VVSG document. These issues will be
discussed in detail during the TGDC Plenary Session on September 29,
2005 in Boulder, Colorado. A crucial task which will allow both EAC and
NIST to most effectively direct scarce resources and to prioritize
upcoming tasks is the development of a comprehensive vulnerability
analysis of electronic voting systems. NIST and the U.S. election
community will begin gathering threat analysis material and information
during the upcoming meeting on this topic scheduled for October 7, 2005
at the NIST complex in Gaithersburg, Maryland.
Recommendation 2: Expeditiously establish documented policies,
criteria, and procedures for certifying voting systems that will be in
effect until the national laboratory accreditation program for voting
systems becomes fully operational; define tasks and time frames for
achieving the full operational capability of the national voting system
certification program.
EAC began the initial transition of the voting system testing and
certification program as required by HAVA by adopting at its August 23,
2005 public meeting a frame work for the interim and future voting
system certification processes. A copy of the document describing the
processes that was adopted by the Commission is attached as Appendix
"2".
The initial task in the interim certification process will be a two-
part transition of the current NASED accredited ITA's to the EAC. Part
one will be a simple documentation and transition process which will
allow the current ITA's to continue testing voting systems to the 2002
VSS. Part two of this task will provide for an interim accreditation
process to ensure that these labs are competent to test to the new
requirements of the 2005 VVSG once that document has been adopted by
EAC.
By October 1, 2005, EAC will begin registering those vendors who intend
to have systems evaluated through the EAC conformance testing process.
An integral component of the EAC's vendor registration process will be
a requirement that vendors notify EAC of problems encountered with
their certified products in the field and to suggest solutions to any
problem encountered. Resources permitting, EAC will consider options to
enhance this program to include investigation and analysis of reported
voting system problems and methods of communicating these issues to the
entire election community.
During this same timeframe, EAC will initiate contractual agreements
with a group of technical experts for the review of voting system test
reports. By January 1, 2006, EAC will be in a position to fully
implement conformance testing of voting systems and to begin the
process of issuing voting system certifications.
Recommendation 3: Improve management support to state and local
election officials by collaborating with NIST to establish a process
for continuously updating the National Software Reference Library for
voting system software; take effective action to promote the library to
state and local governments; identify and disseminate information on
resources to assist state and local governments with using the library;
and assess use of the library by states and local jurisdictions for the
purpose of improving library services.
In 2005, EAC contracted with NIST to develop an interface to the
National Software Reference Library (NSRL) that would be more readily
usable by the state and local election officials. See MOU with NIST
attached as Appendix "Y'. In addition, EAC and NIST seek through the
same agreement to expand the capabilities of the NSRL to allow users to
verify not only EMS software but also software that has been installed
and used on a voting system.
In 2004, EAC began the effort of encouraging voting system vendors to
submit their software versions to the NSRL for cataloging. Upon the
transition of voting system certification to EAC, EAC will require all
vendors who submit voting systems for certification to file their
software with NSRL.
Recommendation 4: Improve management support to state and local
election officials by collaborating with TGDC and NIST to develop a
process and associated timeframes for sharing information on the
problems and vulnerabilities of voting systems.
In its framework for the voting system certification process, EAC has
contemplated the need for information relative to the strengths and
weaknesses, certification and decertification of voting systems. As
such, EAC will introduce additional transparency to the process of
voting system certification and decertification. In addition, EAC has
demonstrated its desire to gather and disseminate data regarding voting
system problems in its 2004 Election Day Survey. Results of that survey
will be released this month and will identify voting system problems
that occurred on election day, as reported by the 50 states and 5
territories.
Recommendation 5: Improve management support to sate and local election
officials by establishing a process and schedule for periodically
compiling and disseminating recommended practices related to security
and reliability management throughout the system life cycle (including
the recommended practices identified in this report) and ensuring that
this process uses information on the problems and vulnerabilities of
voting systems.
In 2005 and 2006, EAC and the National Association of State Election
Directors (NASED) will work together to develop a comprehensive set of
management guidelines that will accompany the Voluntary Voting System
Guidelines. Testing voting systems for conformance to uniform standards
is only half of the equation involved with administering secure
elections. The management processes, physical security, and protocols
used to accept, program, test and maintain voting systems is an equally
important part of conducting fair and accurate elections. The
management guidelines to be developed by EAC and NASED will focus on
these issues.
The United States Election Assistance Commission would like to take the
opportunity to thank GAO for its work, dedication and concern about the
technology and processes that underlie one of America's most precious
freedoms, the right to vote. EAC and GAO join the legions of election
officials throughout the country that work tirelessly to conduct free,
fair and accurate elections.
It has been our pleasure to work with GAO on this historic study and
analysis of our country's voting systems. It is critical that the
federal government and our state and local counterparts analyze the
means by which we conduct elections with the goal of always improving
public confidence and security in our election process. We hope that
the comments offered today will be of assistance to GAO and lend to the
applicability and credibility of its report.
Congress and the nation can rest assured that EAC will continue is
vigilant efforts to help our nation's election officials implement the
requirements of the Help America Vote Act of 2002 and to work to
continually improve our elections.
Sincerely,
Signed by:
Gracia Hillman, Chair:
Paul DeGregorio, Vice Chairman:
Ray Martinez, III:
Donetta Davidson:
[End of section]
Appendix VI: Comments from the National Institute of Standards and
Technology:
UNITED STATES DEPARTMENT OF COMMERCE:
National Institute of Standards and Technology:
Gaithersburg, Maryland 20899-0001:
OFFICE OF THE DIRECTOR:
SEP 09 2005:
Ms. Paula Moore:
Senior Analyst:
United States Government Accountability Office:
Washington, D.C. 20548:
Dear Ms. Moore:
Thank you for the opportunity to comment on the draft report entitled
Elections: Federal Efforts to Improve Security and Reliability of
Electronic Voting Systems Are Under Way, but Key Activities Need to be
Completed (GAO-05-956). We agree wholeheartedly with the report's
conclusions that specific tasks, processes, and time frames must be
established to improve the national voting systems standards, testing
capabilities, and management support available to state and local
election officials.
The 2002 Help America Vote Act (HAVA) established the Technical
Guidelines Development Committee (TGDC) to assist the Election
Assistance Commission (EAC) with the development of voluntary voting
system guidelines. HAVA directs the Commerce Department's National
Institute of Standards and Technology (NIST) director to chair the TGDC
and to provide technical support to the TGDC in the development of
these guidelines. The enclosed comments provide additional details on
DOC/NIST efforts with respect to the security and reliability of
electronic voting systems.
Sincerely,
Signed by:
William Jeffrey:
Enclosure:
[End of section]
Appendix VII: GAO Contacts and Staff Acknowledgments:
GAO Contacts:
David A. Powner, (202) 512-9286 or [Hyperlink, pownerd@gao.gov]
Randolph C. Hite, (202) 512-3439 or [Hyperlink, hiter@gao.gov]:
Staff Acknowledgments:
In addition to those named above, Mark Braza, Barbara Collier, William
Cook, Dan Gordon, Richard Hung, Kevin Jackson, Stanley Kostyla, Linda
Lambert, Paula Moore, Colleen Phillips, Jay Smale, Amos Tevelow, and
Jessica Waselkow made key contributions to this report.
[End of section]
Bibliography:
We selected the following reports, analyses, testimonies, and other
documents because of their relevance to the security and reliability of
electronic voting systems. We used this literature to identify concerns
and recommended practices involving the security and reliability of
voting systems. The first list comprises reports and studies that
include concerns about the security and reliability of voting systems;
the second list comprises reports and studies that include recommended
practices for improving the security and reliability of voting systems.
There was some overlap between the lists in that some of the reports
that identified concerns also suggested mitigating measures to address
these concerns. These mitigating measures are summarized in appendix
II, table 16.
The two lists of studies and reports are not intended to be an
exhaustive compilation of available information or literature in this
area, nor does the presence of a document in these lists imply that it
is endorsed or otherwise recommended. These lists identify primary
sources. Supplementary and corroborating information was gathered from
other reports, testimonies, and through interviews with experts.
Reports and Studies that Include Concerns About the Security and/or
Reliability of Voting Systems:
[1] Coggins, Carolyn, and Gail Audette, SysTest Labs, LLC. "NASED
Independent Test Authority Qualification Testing" (Testimony before the
Environment, Technology, and Standards Subcommittee of the U.S. House
of Representatives' Committee on Science, May 2004).
[Hyperlink,
http://www.house.gov/science/hearings/ets04/jun24/coggins.pdf]
(downloaded July 18, 2005).
[2] Compuware Corporation. Direct Recording Electronic (DRE) Technical
Security Assessment Report (prepared for the Ohio Secretary of State,
November 2003).
[Hyperlink, http://www.sos.state.oh.us/sos/hava/files/compuware.pdf]
(downloaded October 1, 2004).
[3] Compuware Corporation. Diebold Direct Recording Electronic (DRE)
Technical Security Re-Assessment Report (prepared for the Ohio
Secretary of State, August 2004).
[Hyperlink,
http://www.sos.state.oh.us/sos//hava/files/DieboldReassessment.pdf]
(downloaded July 18, 2005).
[4] Coulter, Michael (Chair), Independent Election Committee. Restoring
Confidence to Voters: Findings and Recommendations of the Independent
Election Committee (Mercer County, Penn., February 2005).
[Hyperlink,
http://elections.ssrc.org/data/mercer_co_commission_findings.pdf]
(downloaded July 20, 2005).
[5] Department of State (Pennsylvania), Reexamination Results of
Unilect Corporation's PATRIOT Direct Recording System (April 2005).
[Hyperlink,
http://www.dos.state.pa.us/dos/lib/dos/20/dos_report_unilect_system.pdf]
(downloaded August 8, 2005).
[6] Franklin County Board of Elections. Election 2004: A Report to the
Community (Franklin, County, Ohio, undated).
[Hyperlink,
http://www.electionline.org/Portals/1/Resource%20Library/Franklin.County
.OH.2004.pdf] (downloaded July 18, 2005):
[7] Hursti, Harri. The Black Box Report: SECURITY ALERT July 4, 2005,
Critical Security Issues with Diebold Optical Scan Design (Renton,
Wash., July 2005).
[Hyperlink, http://www.blackboxvoting.org/BBVreport.pdf ] (downloaded
July 5, 2005):
[8] InfoSENTRY Services, Inc. Computerized Voting Systems Security
Assessment: Summary of Findings and Recommendations, volume 1 (prepared
for the Ohio Secretary of State, November 2003).
[Hyperlink, http://www.sos.state.oh.us/sos/hava/files/InfoSentry1.pdf]
(downloaded October 1, 2004).
[9] International Foundation for Election Systems. Unified Monitoring
Report to the Center for Democracy (CFD): International Foundation for
Election Systems (IFES) Team Members, Miami-Dade County, Florida
(Washington, D.C., November 2002).
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(310478):
FOOTNOTES
[1] GAO, Elections: Perspectives on Activities and Challenges Across
the Nation, GAO-02-3 (Washington, D.C.: Oct. 15, 2001); Elections:
Status and Use of Federal Voting Equipment Standards, GAO-02-52
(Washington, D.C.: Oct. 15, 2001); and Elections: A Framework for
Evaluating Reform Proposals, GAO-02-90 (Washington, D.C.: Oct. 15,
2001).
[2] GAO's Executive Council on Information Management and Technology is
made up of leading executives in government, industry, and academia.
[3] EAC, Best Practices Tool Kit (July 2004),
http://www.eac.gov/bp/docs/BestPracticesToolKit.doc.
[4] California Institute of Technology/Massachusetts Institute of
Technology (Caltech/MIT), Immediate Steps to Avoid Lost Votes in the
2004 Presidential Elections: Recommendations for the Election
Assistance Commission (July 2004).
[5] For example, GAO, Federal Information Systems Controls Audit
Manual, GAO/AIMD-12-19.6 (Washington, D.C.: January 1999); NIST,
Generally Accepted Principles and Practices for Securing Information
Technology Systems, SP 800-14 (September 1996) and Security
Considerations in the Information System Development Life Cycle, SP 800-
64, Revision 1 (June 2004); and International Systems Security
Engineering Association, Systems Security Engineering Capability
Maturity Model, ISO/IEC 21827, version 3.0 (June 2003).
[6] The Federal Election Commission used the general term "voting
system standards" for its 2002 publication Voting Systems Performance
and Test Standards. Consistent with HAVA terminology, EAC refers to its
revisions of these standards as Voluntary Voting System Guidelines. For
this report, we refer to the contents of both of these documents as
"standards."
[7] GAO-02-3.
[8] GAO-02-3.
[9] Precinct-count optical scan equipment sits on a ballot box with two
compartments for scanned ballots--one for accepted ballots (i.e., those
that are properly filled out) and one for rejected ballots (i.e., blank
ballots, ballots with write-ins, or those accepted because of a forced
override). In addition, an auxiliary compartment in the ballot box is
used for storing ballots if an emergency arises (e.g., loss of power or
machine failure) that prevents the ballots from being scanned.
[10] GAO-02-3.
[11] According to spokespersons for national advocacy groups for people
with disabilities, only a small percentage of blind people have the
Braille proficiency needed to vote using a Braille ballot.
[12] Using a mouth-held straw, the voter issues switch commands--hard
puff, hard sip, soft puff, and soft sip--to provide signals or
instructions to the voting machine.
[13] The Board of Advisors includes scientific and technical experts
appointed by Congress and representatives from the National Governors
Association; the National Conference of State Legislatures; the
National Association of Secretaries of State; the National Association
of State Election Directors; the National Association of Counties; the
National Association of County Recorders, Election Administrators, and
Clerks; the United States Conference of Mayors; the Election Center;
the International Association of County Recorders, Election Officials,
and Treasurers; the United States Commission on Civil Rights; the
Architectural and Transportation Barrier Compliance Board; the Office
of Public Integrity of the Department of Justice; the Voting Section of
the Department of Justice's Civil Rights Division; and the Federal
Voting Assistance Program of the Department of Defense.
[14] These standards are fundamental to identifying the capabilities
that the laboratories must possess.
[15] Section 102, Help America Vote Act (Oct. 29, 2002).
[16] Sections 101 and 251, Help America Vote Act (Oct. 29, 2002).
[17] Section 101, Help America Vote Act (Oct. 29, 2002).
[18] GAO, Elections: Electronic Voting Offers Opportunities and
Presents Challenges, GAO-04-975T (Washington, D.C.: July 20, 2004).
[19] See bibliographical (bib.) entries 2, 3, 5, and 21. Numbers refer
to primary sources listed in the bibliography. Information presented is
based on both primary sources and supplementary information gathered
from other reports, public testimonies, and interviews with experts.
[20] See bib. entries 2, 7, 21, and 25. Elections and other officials
said that there has never been a proven case of fraud involving
tampering with electronic voting systems. If, however, an attacker (for
instance, a malicious insider) exploited this particular flaw, such
tampering would be difficult to notice and to prove.
[21] See bib. entries 13 and 21. Ballot definition files are not
subject to testing by independent testing authorities.
[22] See bib. entry 21.
[23] See bib. entry 7.
[24] See bib. entries 2, 3, 7, 13, 19, 21, and 22.
[25] See bib. entries 2 and 21.
[26] See bib. entry 2.
[27] See bib. entries 2 and 13.
[28] See bib. entries 7, 13, and 21.
[29] See bib. entries 19, 22, and 26.
[30] See bib. entry 21.
[31] See bib. entry 26.
[32] See bib. entry 2.
[33] See bib. entry 2.
[34] See bib. entries 13 and 19; information supplemented by
interviews.
[35] See bib. entries 18 and 23.
[36] See bib. entry 23; information supplemented by interviews.
[37] Refer to public discussions at TGDC meetings on January 18-19,
2005 (http://www.eastbaymedia.com/tgdc-webcast/) and March 29, 2005
(http://www.eastbaymedia.com/tgdc-march/).
[38] See bib. entries 13 and 18; information supplemented by
interviews.
[39] See bib. entry 18; information supplemented by interviews.
[40] See bib. entries 14, 18, and 19.
[41] See bib. entry 19.
[42] See bib. entries 4 and 25.
[43] See bib. entries 21 and 22.
[44] See bib. entry 16.
[45] See bib. entry 19.
[46] See bib. entry 19.
[47] See bib. entry 25.
[48] See bib. entry 25. Pennsylvania has since decertified this system.
[49] See bib. entries 9 and 17.
[50] See bib. entry 16. The report also notes that several supervisory
procedures were not followed at this precinct, which contributed to the
counting problems.
[51] See bib. entry 6.
[52] See bib. entries 12, 15, and 27.
[53] See bib. entry 1; information supplemented by interview.
[54] See bib. entry 1.
[55] See bib. entries 10 and 24; information supplemented by public
discussion at the TGDC meeting of March 29, 2005
(http://www.eastbaymedia.com/tgdc-march/). According to EAC officials,
the commission plans to address some of these omissions in the new
voluntary system guidelines currently under review.
[56] See bib. entries 10, 12, 15, and 18.
[57] See bib. entries 15 and 27; information supplemented by public
discussion at TGDC meeting on January 18-19, 2005
(http://www.eastbaymedia.com/tgdc-webcast/).
[58] See bib. entries 11 and 15.
[59] See bib. entries 15 and 19.
[60] See bib. entry 19.
[61] See bib. entries 12, 15, 21, and 27; information supplemented by
public discussions at the TGDC meeting on January 18-19, 2005
(http://www.eastbaymedia.com/tgdc-webcast/). Functional testing is done
to ensure that the system performs as expected under normal conditions.
Source code reviews involve an assessment of the code to ensure that it
complies with the 2002 voting system standards and that there are no
hidden functions. Penetration testing involves testers attempting to
circumvent the security controls of a system.
[62] See bib. entries 12, 19, and 27.
[63] See bib. entries 12 and 27.
[64] See bib. entries 12 and 27.
[65] See bib. entries 1, 12, and 27.
[66] See bib. entries 12 and 15.
[67] See bib. entry 12; information supplemented by interviews.
[68] See bib. entries 15, 21, and 27; information supplemented by
interviews.
[69] Information obtained from interviews.
[70] See bib. entry 24; information supplemented by interview.
[71] See bib. entries 18 and 24; information supplemented by
interviews.
[72] See bib. entry 21; information supplemented by public discussion
at the TGDC meeting of March 29, 2005 (http://www.eastbaymedia.com/tgdc-
march/) and interview.
[73] Information obtained from interview.
[74] See bib. entries 1, 22, and 24.
[75] See bib. entries 20 and 24.
[76] See bib. entries 14 and 20.
[77] See bib. entries 2, 8, and 22.
[78] See bib. entries 4, 16, and 19.
[79] See bib. entry 4.
[80] See bib. entries 4, 16, and 19.
[81] Several of the reports we reviewed offered suggestions to address
identified weaknesses. These are summarized in appendix II, table 6.
[82] EAC. Best Practices Tool Kit (July 2004),
http://www.eac.gov/bp/docs/BestPracticesToolKit.doc
(downloaded Oct. 1, 2004).
[83] California Institute of Technology/Massachusetts Institute of
Technology Voting Technology Project. Immediate Steps to Avoid Lost
Votes in the 2004 Presidential Elections: Recommendations for the
Election Assistance Commission (Pasadena, Calif., July 2004).
http://www.vote.caltech.edu/media/documents/EAC.pdf
(downloaded Oct. 1, 2004).
[84] Election officials can verify that systems have met standards by
requesting test reports from the testing laboratories and assessing the
test results.
[85] The 2005 improvements to the voluntary voting system standards
will be named the Voluntary Voting System Guidelines.
[86] Help America Vote Act of 2002, Sections 202 (1) and 221 (b).
[87] Help America Vote Act of 2002, Section 241.
[88] EAC, Best Practices Tool Kit (July 2004),
http://www.eac.gov/bp/index1.asp.
[89] For example, a 1988 National Bureau of Standards report on the
accuracy, integrity, and security of computerized vote-tallying is
still considered relevant.
[90] The documents that were marked as sensitive have been made
available to the public, and thus the markings are no longer
applicable.
[91] Reports and studies that include concerns about the security and
reliability of electronic voting systems are listed separately from
those that identify recommended practices. However, there is some
overlap between the lists in that some of the reports that identified
concerns also recommended measures to address these concerns.
[92] This model identifies key phases in a voting system's life cycle,
including development, acquisition, and operations as well as cross-
cutting activities involving use of standards, testing, and management.
[93] Roy Saltman, NBS SP 500-158: Accuracy, Integrity, and Security in
Computerized Vote-Tallying (Gaithersburg, Md.: National Bureau of
Standards, August 1988). Despite the age of this document, it is still
considered relevant and useful.
[94] The Brennan Center for Justice, Recommendations of the Brennan
Center for Justice and the Leadership Conference on Civil Rights for
Improving Reliability of Direct Recording Electronic Voting Systems,
(Washington, D.C.: June 2004),
http://www.votingtechnology.org/docs/FinalRecommendations.doc?PHPSESSID=
05cc9fce915ccfdaa7aa2a154b5b7a6e
(downloaded Oct. 1, 2004).
[95] Election Center, Accessibility Preparations Checklist (Houston,
Tex.: May 2004); Checklist for Ballot Security (Houston, Tex.: May
2004); Checklist for Polling Place Preparations (Houston, Tex.: May
2004); Recount Procedures (Houston, Tex.: May 2004); and Voting Systems
Checklist (Houston, Tex.: May 2004).
[96] National Task Force on Election Reform, Election 2004: Review and
Recommendations by the Nation's Elections Administrators (Houston,
Tex.: Election Center, May 2005).
[97] Caltech/MIT Voting Technology Project, Voting--What Is, What Could
Be (July 2001).
http://www.vote.caltech.edu/media/documents/july01/July01_VTP_Voting_Rep
ort_Entire.pdf
(downloaded Oct. 1, 2004).
[98] Caltech/MIT Voting Technology Project, Immediate Steps to Avoid
Lost Votes in the 2004 Presidential Election: Recommendations for the
Election Assistance Commission (Pasadena, Calif., July 2004).
http://www.vote.caltech.edu/media/documents/EAC.pdf
(downloaded Oct. 1, 2004).
[99] Tracy Warren, Kelly Ceballos, Lloyd Leonard, and Jeanette Senecal,
Helping America Vote: Safeguarding the Vote (Washington, D.C.: League
of Women Voters, July 2004).
http://www.lwv.org/elibrary/pub/voting_safeguarding_color.pdf
(downloaded Dec. 13, 2004).
[100] GAO, Federal Information System Controls Audit Manual, GAO/AIMD-
12.19.6 (Washington, D.C.: January 1999).
[101] GAO, Information Security Risk Assessment: Practices of Leading
Organizations, GAO/AIMD-00-33 (Washington, D.C.: November 1999).
[102] CERT Coordination Center, CERTŪ Security Improvement Modules
(Carnegie Mellon University, undated), http://www.cert.org/security-
improvement/.
[103] SANS, www.sans.org.
[104] SANS, www.sans.org/rr/.
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