Elections: Federal Efforts to Improve Security and Reliability of
Electronic Voting Systems Are Under Way, but Key Activities Need
to Be Completed (21-SEP-05, GAO-05-956).
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.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-05-956
ACCNO: A37777
TITLE: Elections: Federal Efforts to Improve Security and
Reliability of Electronic Voting Systems Are Under Way, but Key
Activities Need to Be Completed
DATE: 09/21/2005
SUBJECT: Computer security
E-government
Elections
Intergovernmental relations
Internal controls
Systems analysis
Systems design
Systems development life cycle
Systems evaluation
Testing
Strategic planning
Electronic equipment
Standards evaluation
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GAO-05-956
* 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
* Contents
* Results in Brief
* Background
* Electronic Voting Systems Support Vote Casting and Counting
* HAVA Is Expected to Enhance the Federal Role in Election
Processes
* Security and Reliability Are Important Elements Throughout
the Voting System Life Cycle
* Significant Concerns Have Been Raised about the Security and
Reliability of Electronic Voting Systems
* Product Development
* Election Operations
* Standards
* Voting System Testing
* Security Management
* Recommended Practices Address Electronic Voting Systems' Security
and Reliability
* Product Development
* Acquisition
* Operations
* Standards
* Testing
* Management
* National Initiatives Are Under Way to Improve Voting System
Security and Reliability, but Key Activities Need to Be Completed
* Federal Initiatives to Improve Voting Systems Security and
Reliability Are Under Way
* Tasks and Time Frames for Completing Federal Initiatives Are
Not Fully Defined
* Nongovernmental Initiatives Are Intended to Improve Voting
System Security and Reliability
* Conclusions
* Recommendations for Executive Action
* Agency Comments and Our Evaluation
* Objectives, Scope, and Methodology
* Selected Recommended Practices for Voting System Security and
Reliability
* Summary of Selected Guidance on Information Technology Security and
Reliability
* Resolutions Related to Voting System Security and Reliability
* Comments from the Election Assistance Commission
* Comments from the National Institute of Standards and Technology
* GAO Contacts and Staff Acknowledgments
* Bibliography
United States Government Accountability Office
Report to Congressional Requesters
GAO
September 2005
ELECTIONS
Federal Efforts to Improve Security and Reliability of Electronic Voting Systems
Are Under Way, but Key Activities Need to Be Completed
a
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
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
o Cast ballots, ballot definition files, and audit logs o Local
jurisdictions misconfigured their could be modified. electronic voting
systems, leading to
o Supervisor functions were protected with weak election day problems.
or easily guessed passwords. o Voting systems experienced
operational
o Systems had easily picked locks and power failures during elections.
switches that were exposed and unprotected. o Vendors installed
uncertified electronic voting systems.
United States Government Accountability Office
Contents
Letter 1
Results in Brief 2 Background 5 Significant Concerns Have Been Raised
about the Security and
Reliability of Electronic Voting Systems 22 Recommended Practices Address
Electronic Voting Systems'
Security and Reliability 38 National Initiatives Are Under Way to Improve
Voting System
Security and Reliability, but Key Activities Need to Be
Completed 43 Conclusions 53 Recommendations for Executive Action 53 Agency
Comments and Our Evaluation 54
Appendixes
Appendix I: Appendix II: Appendix III: Appendix IV: Appendix V: Appendix
VI: Appendix VII:
Objectives, Scope, and Methodology 60 Selected Recommended Practices for
Voting System Security and Reliability 63 Summary of Selected Guidance on
Information Technology Security and Reliability 78 Resolutions Related to
Voting System Security and Reliability 84 Comments from the Election
Assistance Commission 86 Comments from the National Institute of Standards
and Technology 92 GAO Contacts and Staff Acknowledgments 93
Bibliography
Table 1: Common Types of Security and Reliability Concerns
Tables
Viewed in Terms of the Voting System Life Cycle 24 Table 2: Federal
Initiatives Related to Improving the Security and Reliability of Voting
Systems 44
Page i GAO-05-956 Electronic Voting Systems
Contents
Table 3: Nongovernmental Initiatives to Improve Voting System
Security and Reliability 51
Table 4: EAC Security and Reliability Practices for All Types of
Voting Systems 64
Table 5: EAC Security and Reliability Practices for Optical Scan
Voting Systems 65
Table 6: EAC Security and Reliability Practices for Direct
Recording Electronic Voting Systems 66
Table 7: NIST Security and Reliability Practices for Electronic
Voting Systems 67
Table 8: Brennan Center Example Security and Reliability
Practices for Direct Recording Electronic Voting
Systems 68
Table 9: Election Center Security and Reliability Practices for
Elections 69
Table 10: National Task Force on Election Reform Security and
Reliability Practices for Voting Systems 71
Table 11: Caltech/MIT Security and Reliability Practices for Voting
Systems 73
Table 12: Caltech/MIT Security and Reliability Practices for
Electronic Voting Systems 74
Table 13: League of Women Voters Security and Reliability Practices
for All Voting Systems 75
Table 14: League of Women Voters Security and Reliability Practices
for Optical Scan Voting Systems 76
Table 15: League of Women Voters Security and Reliability Practices
for Direct Recording Electronic Voting Systems 76
Table 16: A Compendium of Recommended Mitigation Measures to
Address Selected Concerns with Electronic Voting
Systems' Security and Reliability 77
Table 17: Examples of NIST Publications Addressing System
Security and Reliability 79
Table 18: Resolutions Related to Security and Reliability of
Electronic Voting Systems and Plans for Implementing
Them in Future Standards 84
Figure 1:
Figures
Figure 2: Figure 3:
Page ii
Stages of an Election Process 7
Precinct-Count Optical Scan Tabulator and Central-Count
Optical Scan Tabulator 9
Two Types of DRE Systems-Pushbutton and
Touchscreen 11
Contents
Figure 4: States Requiring the Use of Federal Voting System
Standards and States Requiring National Certification
Testing 18
Figure 5: A Voting System Life Cycle Model 20
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
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A
United States Government Accountability Office Washington, D.C. 20548
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.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
1GAO, 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).
Results in Brief
Management and Technology.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.
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.
2GAO's Executive Council on Information Management and Technology is made
up of leading executives in government, industry, and academia.
Page 2 GAO-05-956 Electronic Voting Systems
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.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.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.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.
3EAC, Best Practices Tool Kit (July 2004),
http://www.eac.gov/bp/docs/BestPracticesToolKit.doc.
4California 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).
5For 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).
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 standards6 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
6The 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."
Page 4 GAO-05-956 Electronic Voting Systems
Background
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.
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.7
7 GAO-02-3.
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.8
Administering an election is a year-round process involving the following
stages:
o 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.
o 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.
o 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.
8 GAO-02-3.
o 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
Source: GAO analysis.
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 scan9-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.
9Precinct-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.
Page 8 GAO-05-956 Electronic Voting Systems
Figure 2: Precinct-Count Optical Scan Tabulator and Central-Count Optical
Scan Tabulator
Source: Equipment vendors.
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
Source: Local election officials and equipment vendor.
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,10 we reported that the following features
were available on some models of DRE:
o 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.
o A "review" feature. This feature requires voters to review each page
of the ballot before pressing the button to cast the vote.
10GAO-02-3.
HAVA Is Expected to Enhance the Federal Role in Election Processes
o Visual enhancements. These features include, for example, color
highlighting of ballot choices and candidate pictures.
o Accommodations for voters with disabilities. Examples of options for
voters who are blind include Braille keyboards and audio interfaces.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.12 Another option is voice recognition capability,
which allows voters to make selections orally.
o 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.
o An option to provide printed receipts. This option, provided by a
voterverified 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.
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.
11According 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.
12Using 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.
Page 14 GAO-05-956 Electronic Voting Systems
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
o adopting and maintaining voluntary voting system guidelines;
o managing a national program for testing, certification,
decertification, and recertification of voting system hardware and
software;
o 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:
o 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.
o 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.
o The Board of Advisors is made up of 37 members-many from various
professional and specialty organizations.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.
o 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
13The 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.
advisory boards before voting on the standards. EAC and its boards are
also to consider updates to the standards on an annual basis.
o 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.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.
o 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.
14These standards are fundamental to identifying the capabilities that the
laboratories must possess.
Page 17 GAO-05-956 Electronic Voting Systems
Figure 4: States Requiring the Use of Federal Voting System Standards and States
Requiring National Certification Testing
Source: GAO analysis of EAC data.
Note: State requirements are based on EAC assessment of state statute and
administrative rule.
Resources. HAVA authorized federal payments to help states improve their
voting systems in two ways:
o 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, 2006.15 EAC reports
that approximately $300 million was distributed to 30 states under this
HAVA provision-all in fiscal year 2003.
15Section 102, Help America Vote Act (Oct. 29, 2002).
* 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);16
upgrading systems in general; improving the administration of
elections; or educating voters and training election workers (among
other things).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
o EAC commissioners be appointed no later than 120 days after the law
was enacted,
o 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,
o 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,
o EAC approve voluntary guidance for certain voting system standards by
January 2004,
o NIST conduct evaluations of independent testing laboratories for
accreditation within 6 months of the adoption of updated voting
standards,
o 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
o 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.
16Sections 101 and 251, Help America Vote Act (Oct. 29, 2002). 17Section
101, Help America Vote Act (Oct. 29, 2002).
Page 19 GAO-05-956 Electronic Voting Systems
Security and Reliability Are Important Elements Throughout the Voting System
Life Cycle
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.
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
Product development Acquisition Operations
Testing National standards
Management
Sources: GAO analysis of NIST, IEEE, and EAC publications.
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
Significant Concerns Have Been Raised about the Security and Reliability of
Electronic Voting Systems
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.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.
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
18GAO, Elections: Electronic Voting Offers Opportunities and Presents
Challenges, GAO-04-975T (Washington, D.C.: July 20, 2004).
Page 22 GAO-05-956 Electronic Voting Systems
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 Common concerns
Product development o Weak system security controls
o Design flaws in voter-verified paper audit trail systems
o Weak security management practices
Acquisition No significant concerns reported
Operations o Incorrect system configuration
o Poor implementation of security procedures
o System failures during elections
Standards o Vague and incomplete security provisions
o Inadequate provisions for commercial off-the-shelf systems and
telecommunications and networking services
o Inadequate requirements for vendor documentation
Testing o Inadequate security testing
o Lack of transparency in the testing process
Management o Poor version control of system software
o Inadequate security management
Source: GAO analysis and summary.
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.
o 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).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.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.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.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.23 If exploited, these
weaknesses could damage the integrity of ballots, votes, and voting system
software by allowing unauthorized modifications.
19See 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.
20See 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.
21See bib. entries 13 and 21. Ballot definition files are not subject to
testing by independent testing authorities.
22See bib. entry 21.
23See bib. entry 7.
o Regarding access controls, many security examinations reported flaws in
how controls were implemented in some DRE systems.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.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.26
Reviewers also found that values used to encrypt election data (called
encryption keys) were defined in the source code.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.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.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.
24See bib. entries 2, 3, 7, 13, 19, 21, and 22. 25See bib. entries 2 and
21. 26See bib. entry 2. 27See bib. entries 2 and 13. 28See bib. entries 7,
13, and 21. 29See bib. entries 19, 22, and 26.
o 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.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.31
In another report, reviewers were concerned that a particular model of DRE
was linked together with others to form a rudimentary network.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.33
30See bib. entry 21. 31See bib. entry 26. 32See bib. entry 2. 33See bib.
entry 2.
Page 27 GAO-05-956 Electronic Voting Systems
Design flaws in the voter-verified paper audit trail systems.
Voterverified 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.34 However, other election
officials and researchers have raised concerns about potential reliability
and security flaws in the design of such systems.35 Critics of the systems
argue that adding printers increases the chance of mechanical failure and
disruption to the polling place.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.37 If not protected, such
information could breach voter confidentiality.
34See bib. entries 13 and 19; information supplemented by interviews.
35See bib. entries 18 and 23. 36See bib. entry 23; information
supplemented by interviews. 37Refer 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/).
Election Operations
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.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.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.40 A committee of election system
vendors generally disagrees with these concerns and asserts that their
security management practices are sound.
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.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.42 This error contributed to many votes not being
38See bib. entries 13 and 18; information supplemented by interviews.
39See bib. entry 18; information supplemented by interviews. 40See bib.
entries 14, 18, and 19. 41See bib. entry 19. 42See bib. entries 4 and 25.
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.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.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.45
43See bib. entries 21 and 22. 44See bib. entry 16. 45See bib. entry 19.
Page 30 GAO-05-956 Electronic Voting Systems
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.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.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.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.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.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.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
46See bib. entry 19. 47See bib. entry 25. 48See bib. entry 25.
Pennsylvania has since decertified this system. 49See bib. entries 9 and
17. 50See bib. entry 16. The report also notes that several supervisory
procedures were not
followed at this precinct, which contributed to the counting problems.
51See bib. entry 6.
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.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.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.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
52See bib. entries 12, 15, and 27. 53See bib. entry 1; information
supplemented by interview. 54See bib. entry 1.
Page 32 GAO-05-956 Electronic Voting Systems
on technologies such as wireless networking and voter-verified paper audit
trails. 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.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.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.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
55See 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.
56See bib. entries 10, 12, 15, and 18.
57See bib. entries 15 and 27; information supplemented by public
discussion at TGDC meeting on January 18-19, 2005 (
http://www.eastbaymedia.com/tgdc-webcast/).
58See bib. entries 11 and 15.
Voting System Testing
documentation for local officials with respect to proper operation and
maintenance procedures.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.60
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.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.
o 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.62 They argue that functional tests only
59See bib. entries 15 and 19.
60See bib. entry 19.
61See 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.
62See bib. entries 12, 19, and 27.
measure a system's performance when it is used as expected, under normal
operating conditions.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.64 As a result, malicious code could be present in a system
and evade testing as long as the triggering commands were not entered.
o 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.65 Moreover, there is concern that these code reviews may not
adequately inspect how voting system software interacts with key
election data.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.67
o As for penetration testing, experts expressed concerns that voting
system testing does not include such explicit security tests.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
63See bib. entries 12 and 27. 64See bib. entries 12 and 27. 65See bib.
entries 1, 12, and 27. 66See bib. entries 12 and 15. 67See bib. entry 12;
information supplemented by interviews. 68See bib. entries 15, 21, and 27;
information supplemented by interviews.
Security Management
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.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.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.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,72 one security expert noted that a system should be
secure enough to resist even a knowledgeable attacker.73
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
69Information obtained from interviews. 70See bib. entry 24; information
supplemented by interview. 71See bib. entries 18 and 24; information
supplemented by interviews. 72See bib. entry 21; information supplemented
by public discussion at the TGDC meeting of
March 29, 2005 (http://www.eastbaymedia.com/tgdc-march/) and interview.
73Information obtained from interview.
qualified and certified at the national or state levels.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.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.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.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.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.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
74See bib. entries 1, 22, and 24. 75See bib. entries 20 and 24. 76See bib.
entries 14 and 20. 77See bib. entries 2, 8, and 22. 78See bib. entries 4,
16, and 19. 79See bib. entry 4.
Recommended Practices Address Electronic Voting Systems' Security and
Reliability
adequate technical skills or knowledge of their particular systems to
manage, administer, and troubleshoot them.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.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.
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
80See bib. entries 4, 16, and 19.
81Several of the reports we reviewed offered suggestions to address
identified weaknesses. These are summarized in appendix II, table 6.
Page 38 GAO-05-956 Electronic Voting Systems
elections experts, including state and local jurisdictions.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.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
electionspecific publications' guidance on voting system security and
reliability practices, and appendix III provides summaries of general
guidance on information systems security.
82EAC. Best Practices Tool Kit (July 2004), h
ttp://www.eac.gov/bp/docs/BestPracticesToolKit.doc (downloaded Oct. 1,
2004).
83California 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). h
ttp://www.vote.caltech.edu/media/ documents/EAC.pdf (downloaded Oct. 1,
2004).
Product Development
o Voting system developers should define security requirements and
specifications early in the design and development process.
o 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.
o 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.
o 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.
o Vendors should review lessons learned from recent elections and
implement relevant mitigation steps to address known security
weaknesses (see app. II, table 16).
Acquisition
o Election officials should focus on the security issues related to
electronic voting equipment before purchasing or implementing voting
systems.
o Requests for proposals should include security requirements and
evaluation and test procedures.
o 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 o 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.
Page 40 GAO-05-956 Electronic Voting Systems
o 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.
o Voting machines, ballots, memory cartridges, election supplies, and
offices should be physically secured against unauthorized access
before, during, and after an election.
o A postelection audit of voting systems should be conducted to
reconcile vote totals and ballot counts, even if there is no recount
scheduled.
o 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 o States should adopt the most current version of the national
voluntary voting standards or guidelines.
Testing
o 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.
o During the acquisition phase, states and local governments should
require that voting systems be certified against federal standards.
o 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 o 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.
o Voting system developers should conduct appropriate background
screening on all employees before granting them access to sensitive
information or placing them into sensitive positions.
o 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.
o 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.
o Election officials should conduct a risk analysis of voting systems
and address any identified vulnerabilities and points of failure in
the election process.
o 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.84
o 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.
84Election officials can verify that systems have met standards by
requesting test reports from the testing laboratories and assessing the
test results.
Page 42 GAO-05-956 Electronic Voting Systems
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
Actual or planned completion
Initiative Responsibility Status date
Standards
Draft initial set of voluntary voting TGDC Completed May 2005 (actual)
system
guidelines (HAVA)
Adopt voluntary guidance for EAC In process Fall 2005
certain voting system
standards (HAVA)
Complete security and TGDC recommends; In process Not determined
reliability updates to
voting system guidelines EAC approves
Testing
Conduct evaluation of NIST Not yet By early 2007
independent testing initiated
laboratories for accreditation
(HAVA)
Accredit first cadre of NIST recommends; Not yet By early 2007
independent voting system EAC approves initiated
testing laboratories (HAVA)
Define interim process for EAC In process Fall 2005
certification of voting
systems
Establish national program EAC In process Not determined
for voting system
certification (HAVA)
Management support
Establish national reference NIST Completed July 2004
library for certified voting (actual)
system software
Establish procedures for NIST recommends; In process Not determined
sharing problems associated EAC approves
with voting systems
Provide an initial report EAC Completed August 2004
that includes best practices (actual)
for secure and reliable
voting systems
Provide periodic reports on EAC In process First report by
election administration December 2006;
practices (HAVA) 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.
Standards. TGDC and NIST have been working on behalf of EAC to improve the
2002 Federal Election Commission voluntary voting system standards85 and
their impact on the acquisition, testing, operations, and management
processes of the voting system life cycle.86 TGDC approved 41
85The 2005 improvements to the voluntary voting system standards will be
named the Voluntary Voting System Guidelines.
86Help America Vote Act of 2002, Sections 202 (1) and 221 (b).
Page 44 GAO-05-956 Electronic Voting Systems
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
o a method for distributing voting system software,
o protocols for generating and distributing software reference data for
the NIST repository of certified voting system software,
o a method for validating the proper setup of voting systems,
o controls for the use of wireless communications by voting systems, and
o 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.
o 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.
o 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.
o 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.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.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.
87Help America Vote Act of 2002, Section 241. 88EAC, Best Practices Tool
Kit (July 2004), h ttp://www.eac.gov/bp/index1.asp.
Page 48 GAO-05-956 Electronic Voting Systems
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
Nongovernmental Initiatives Are Intended to Improve Voting System Security
and Reliability
commission. As a result, it is unclear when the results of these
initiatives will be available to assist state and local election
authorities.
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
Initiative Organization Product or activity Status
Product development
Prototype for Open Voting Developed a prototype for Continuing to add
an an open-source electronic
Consortium voting application that functionality to
open-source uses commercial hardware prototype. No
and
electronic operating system components specific timetable.
voting and provides (1) an
application 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.
A Modular Caltech/MIT Proposed an approach for Completed August
Voting Voting building additional security 2001.
Architecture Technology features into electronic voting Available for
Project systems through an implementation.
alternative voting system
architecture.
Acquisition
A Framework for National Academy of Defining questions Publication
to help policy expected in fall
makers, election
officials,
Understanding Sciences' Computer and the interested 2005.
public understand
the technology,
Electronic Science and social, and
Voting operational issues
relevant to
electronic voting,
Telecommunications including security
issues.
Board
Started an
Relative Brennan Center for independent To be completed in
assessment of fall 2005.
electronic voting
performance of Justice system security and
plans to develop a
report describing
voting system the relative
performance of each
class of voting
systems.
classes
(Continued From Previous Page)
Initiative Organization Product or activity Status
Standards
Project 1583 Institute of Developing a standard for Project 1583
on Electrical voting equipment members in
requirements
Voting and Electronics and evaluation methods, recess. No
Equipment including security and current plans to
reliability
Standards Engineers characteristics. resume this
project's
activities.
Project 1622 Institute of Developing data formats to Project 1622
on Electrical be used by voting system officials are
Voting and Electronics components for exchange of working to
Equipment electronic data, including endorse a draft
Electronic Engineers data related to secure and standard. No
Data reliable system specific
operations.
Interchange timetable.
Election Organization Defined process and data Officials are
Markup for the requirements that include seeking approval for
Language Advancement of security considerations for this markup language
Structured authentication, as an international
Information privacy/confidentiality, and standard from the
Standards integrity. International
Organization for
Standardization. No
specific timetable.
Testing
Voting System Voting System Developing evaluation Working groups
Performance Performance Rating and performance are being
Rating assessment tests for use organized and
in rating the members plan to
performance of voting draft, publish,
systems in subject areas and distribute a
such as privacy, range of
transparency, and ballot documents in
verifiability. each of the
relevant subject
areas over the
next 2 years.
Management
Professional The Election Created a professional Continuing to
Center education program expand the
designed to
Education provide training and curriculum. No
Program certification to specific
election officials and
vendors. timetable.
Election Operating the Election Plans to operate
Incident Verified Voting Incident Reporting through
System, a Web-
Reporting System based system to future elections.
collect and No specific
disseminate
information
about local voting timetable for
systems and election supporting
irregularities.
activities.
Operating a repository
Information VotersUnite! of news and events and Ongoing postings.
a
clearinghouse newsletter service to Continuation
share information uncertain due to
among advocacy
groups and limited
jurisdictions on a resources.
wide range of
electronic
voting problems and
issues.
Created a federally Plans to conduct
A Center for Johns Hopkins funded center that is activities
to conduct
Correct, Usable, University (1) research into the over 5 years.
technological issues
facing electronic
Reliable, voting, (2) education
Auditable, efforts, aimed at
higher education,
and Transparent focusing on voting
technology issues, and
(3) outreach to
Elections stakeholders in the
election
administration
process,
including vendors,
election officials,
and community
groups.
Source: GAO summary of data provided by organizations listed above.
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 securityrelated
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.
To improve the potential for benefits to states and local election
Recommendations for
jurisdictions, we recommend that the Election Assistance Commission take
the following five actions:
Page 53 GAO-05-956 Electronic Voting Systems
Agency Comments and Our Evaluation
ds required to improve the voting system standards
that affect security and reliability of voting systems.
ational, and define tasks and time frames for achieving the
full operational capability of the national voting system
certification program.
o 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.
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
h ttp://www.gao.gov.
Should you have any questions about matters discussed in this report,
please contact Dave Powner at (202) 512-9286 or at p [email protected] or
Randy Hite at (202) 512-3439 or at h [email protected]. 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.
David A. Powner
Director, Information Technology Management Issues
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
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
Appendix I Objectives, Scope, and Methodology
work.1 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.2 The final lists of the selected
literature we relied on for our work are shown in the bibliography.3 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.4
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
1For example, a 1988 National Bureau of Standards report on the accuracy,
integrity, and security of computerized vote-tallying is still considered
relevant.
2The documents that were marked as sensitive have been made available to
the public, and thus the markings are no longer applicable.
3Reports 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.
4This 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.
Appendix I Objectives, Scope, and Methodology
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.
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.
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
Table 4: EAC Security and Reliability Practices for All Types of Voting Systems
Life cycle activity Example practice
Acquisition o 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.
o 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.
Operations o Draft and implement well-organized procedures that identify
the chain of custody for every instance when the ballots and/or voting
equipment changes hands.
o Separate staff duties for each test you conduct, and require staff
signatures to ensure each procedure has been completed and
appropriately documented.
o 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.
o 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.
o Conduct a postelection audit of all electronic systems.
o Verify that the number of ballots cast matches the number of voters
who signed each precinct's roster.
o Develop administrative procedures (or implement those procedures
developed by state officials) to audit the accuracy of your election
results.
o 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.
Testing o To reduce the risk of raising public concerns, conduct
pre-testing before conducting a public test to ensure that the machines
are working properly.
o 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.
Management o Focus early on poll worker recruitment and training; poll
workers should practice each important component of the election process,
especially using the voting equipment.
o Include chain of custody instructions in poll worker training.
o Prepare back-up and emergency plans; conduct a risk analysis of the
election process and develop a plan for dealing with worst-case
scenarios.
o If introducing a new voting system, conduct voter and media outreach.
Develop brochures; set up selfhelp 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.
o Request that your vendor submits its certified software to the
National Software Reference Library (NSRL) at the National Institute
of Standards and Technology (NIST).
o 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.
o 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.
o 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.
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
Table 5: EAC Security and Reliability Practices for Optical Scan Voting Systems
Life cycle activity Example practice
Operations o Establish security procedures for printing and shipping of
ballots.
o 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.
o Have two poll workers transport results.
Testing o Test the calibration of every scanner before the election.
o Conduct printing tests and quality control tests.
Management o If using in-precinct counting system, provide poll workers
with a script for assisting the voter without compromising voter privacy.
o Provide poll worker training on ballot and equipment storage
requirements and security measures.
o Develop a troubleshooting plan. Define the response time-know how long
it will take to get a troubleshooter to the polling place.
o Establish procedures for handling a machine failure, such as roving
technicians, a technical help desk, and technical back-up support.
o 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.
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
Table 6: EAC Security and Reliability Practices for Direct Recording Electronic
Voting Systems
Life cycle activity Example practice
Operations o 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. o 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. o Keep a maintenance log for all voting
system equipment. This log should track who has had
access to the machines. o Develop chain of custody
for memory cards and machines. o Control access to
the voter "smart cards." o Develop rules for access
to any sensitive equipment. o 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.
Testing o Conduct, at a minimum, both acceptance testing and
logic and accuracy testing on each system. Logic and
accuracy testing should include "incremental testing."
o Conduct system diagnostics on every machine for
every election before you conduct logic and accuracy
testing. o Conduct postelection logic and accuracy
testing of machines.
Management o Create a poll worker position that is dedicated to
machine setup, shutdown, and troubleshooting. Provide
supplemental training on equipment; supplement pay for
extra training. o Establish written procedures for
handling election day equipment failure. o 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. o Ensure that all
software, including patches, is certified.
Source: GAO summary and categorization of EAC report.
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.1 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.
1Roy 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.
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Table 7: NIST Security and Reliability Practices for Electronic Voting Systems
Life cycle activity Example practice
Product development o 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.
o 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.
Operations o 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.
o 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.
o 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 voterchoice sets, and postelection
checkout of machines.
Standards o Each state should consider the adoption of the Federal
Election Commission clearinghouse specifications.
Testing o 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.
o Vote-tallying software should be tested for logical correctness.
o 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.
o Sufficient pre-election testing should be done so that errors in
software specialization or in implementation of logical rules, if any,
will become obvious.
Management o 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.
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 2004.2 The recommendations are high-level
2The 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=05cc9fce9
15ccfdaa7aa2a154b5b7a6e (downloaded Oct. 1, 2004).
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Appendix II Selected Recommended Practices for Voting System Security and
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policy recommendations and broad procedural statements rather than
lowlevel 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 Example practice
Operations o 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.
Testing o Elections officials should develop procedures for random
parallel testing of the voting systems in use to detect malicious code or
bugs in the software.
Management o 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.
o 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.
o 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.
o 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.
o All jurisdictions should prepare and follow standardized procedures
for response to alleged or actual security incidents that include
standardized reporting and publication.
o 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.
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.3 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
3Election 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).
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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 Example practice
Operations Ballot security:
o Are the polling place scanners/tabulators zeroed and sealed, and the
seal number recorded?
o 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:
o Have you prepared a list of duties (in time frame sequence) that need
to be accomplished in order to secure polling locations?
o Does the facility have sufficient electrical outlets? Voting systems:
o Have labels been printed for memory cards/tabulation chips, receipt
envelopes, machine tapes, envelopes, etc.?
o Have all peripheral voting supplies been packed, proofed, and secured?
Recount procedures:
o Keep an audit log of equipment programming, including the retention of
all nightly backups until after the deadline for recounts has passed.
o Make certain all ballot containers are sealed, labeled, and accounted
for.
o Schedule recount. Establish complete calendar of events.
o Open sealed containers only when recount board and observers are
present.
o If manual count differs from the original results, you may want to
have a different recount team validate the results.
o 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.
Testing Ballot security:
o Has logic and accuracy testing been completed? Voting systems:
o 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:
o Keep an audit log of all equipment testing.
o 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.
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
(Continued From Previous Page)
Life cycle activity Example practice
Management Polling place preparations:
o Have you prepared a poll worker manual?
o Have you prepared training materials, including audio-visual
materials? Voting systems:
o Have pertinent federal laws that affect voting systems been researched
for an understanding of requirements?
o Have training materials for election workers been prepared and
printed?
o Have election workers been notified and assigned to training classes?
o Are you on the latest, tested, certified version of your voting system
software?
Source: GAO summary and categorization of Election Center report.
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 2005.4 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.
4National Task Force on Election Reform, Election 2004: Review and
Recommendations by the Nation's Elections Administrators (Houston, Tex.:
Election Center, May 2005).
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Table 10: National Task Force on Election Reform Security and Reliability
Practices for Voting Systems
Life cycle activity Example practice
Acquisition In the area of procurement of equipment, the task force
recommends:
o That the EAC develop and maintain a library of requests for proposals
(RFPs), contracts, and customer complaints as a resource for
purchasing jurisdictions.
o That states are encouraged to assist in procuring voting equipment for
local jurisdictions.
o That purchasing jurisdictions carefully and thoroughly document each
step of the procurement process.
o 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.
Operations In the area of Voter Verifiable Paper Audit Trail, the task
force recommends:
o That states develop procedures to safeguard and retain any paper record
receipt in the polling place to preserve secrecy of the voted ballot.
Standards 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:
o 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.
o 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.
Testing In the area of logic and accuracy testing, the task force
recommends:
o 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.
o That the date and location of logic and accuracy testing be publicized
through media releases and public Web pages.
o That NIST provide testing standards and procedures by equipment type
for use by local and state election administrators in conducting logic
and accuracy testing.
o That local election administrators develop internal staffing
procedures to control, manage, and document the logic and accuracy
testing of their jurisdiction's voting equipment.
Management 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:
o 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.
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
Caltech/MIT Voting Technology Project: Voting-What Is, What Could Be. The
Caltech/MIT Voting Technology Project issued its first report in July
2001.5 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 highlevel 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.
5Caltech/MIT Voting Technology Project, Voting-What Is, What Could Be
(July 2001).
h
ttp://www.vote.caltech.edu/media/documents/july01/July01_VTP_Voting_Report_Entire.
pdf (downloaded Oct. 1, 2004).
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Table 11: Caltech/MIT Security and Reliability Practices for Voting Systems
Life cycle activity Example practice
Product development o Move away from complex, monolithic machines, to
systems using a simple electronic voterecording device that is separate
from other parts of the system.
o Make source code for all vote recording and vote counting processes
open source and source code for the user interface proprietary.
o Design equipment that logs all events (votes, maintenance, etc.) that
occur on the machine.
Acquisition o 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.
Operations o Conduct audits of votes and equipment, even without a
recount.
o 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.
Standards o The federal government should create and operate a National
Election Standards Commission to use historically proven methods to
develop standards.
o 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
Testing o The federal government should establish a program for field
testing all voting equipment and standard ballot formats.
Management o Train election officials in the interior workings of their voting
equipment.
Source: GAO summary and categorization of Caltech/MIT report.
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.6 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,
6Caltech/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). h
ttp://www.vote.caltech.edu/media/documents/EAC.pdf (downloaded Oct. 1,
2004).
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Appendix II Selected Recommended Practices for Voting System Security and
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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 Example practice
Operations o The EAC should require from each election jurisdiction
(county and state) a report of total ballots cast and votes cast for each
federal office.
o All election jurisdictions should also report on the voting
technologies they use for precinct and absentee voting in each federal
election.
o Audit logs of individuals with access to the computer must be
performed and retained after each election.
o Computers used for elections should be restricted to the sole purpose
of election administration, and not used for other purposes.
o 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.
o Election machines (and ballots where ballots exist) should be well
secured. Ideally, numbered seals should be used as closures for the
equipment.
o In-precinct counting machines should not turn off the ballot overvote
and error checking features of these machines.
Testing o 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.
o 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.
o A random sample of voting machines should be tested in voting mode as
though it were the day of the election.
Management o Poll workers should be trained with procedure-oriented
teaching materials and have ways of looking up answers to important
questions in a reasonable time.
o 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.
o 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.
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
League of Women Voters: Safeguarding the Vote. In July 2004 the League of
Women Voters produced a report7 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 Example practice
Operations o Require bipartisan or third-party monitoring of sensitive
election procedures.
o Require tracking and documentation of all procedures from the testing
of machines to the handling of ballots.
o Restrict physical access to all components of voting systems.
o Ballots, voting machines, memory cartridges, and counting machines
should never be left unattended.
o Preferably two election officials will oversee all processes,
including the transfer of ballots and other election materials to the
central office.
o 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.
o Maintain and operate voting systems in isolation from networks and the
Internet.
Testing o Require that all systems, at a minimum, have been state
certified and meet all federal voluntary voting system standards.
o Test every voting machine to ensure it is operating properly.
o Perform uniform, public testing of voting systems.
o Test voting machines and counting machines, including their hardware
and software, before election day. Carry out testing in a public
process.
7Tracy Warren, Kelly Ceballos, Lloyd Leonard, and Jeanette Senecal,
Helping America Vote: Safeguarding the Vote (Washington, D.C.: League of
Women Voters, July 2004). h
ttp://www.lwv.org/elibrary/pub/voting_safeguarding_color.pdf (downloaded
Dec. 13, 2004).
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(Continued From Previous Page)
Life cycle activity Example practice
Management o Educate voters on the use of all voting equipment both in
advance of the election and in the polling place on election day.
o Establish statewide practices for the management and operation of
voting systems.
o 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.
o Do not remove machines from the polls for repairs or for any other
reason until voting has ended.
o Provide a back-up plan in the event of machine failure.
o Establish statewide practices for the management and operation of
voting systems.
o 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.
Table 14: League of Women Voters Security and Reliability Practices for Optical
Scan Voting Systems
Life cycle activity Example practices
Testing o Ensure that scanners are properly calibrated before election day.
Management o Both in-person and absentee voters should receive
instructions on what constitutes a spoiled ballot and what to do if they
spoil their ballot.
o 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.
Table 15: League of Women Voters Security and Reliability Practices for Direct
Recording Electronic Voting Systems
Life cycle activity Example practices
Operations o On election day, periodically check to make sure machines
are properly calibrated and that cords remain plugged into their sockets.
o 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.
Testing o Test audio and magnification systems for each machine.
Source: GAO summary and categorization of League of Women Voters report.
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
Appendix II Selected Recommended Practices for Voting System Security and
Reliability
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 Proposed mitigation measure
Jurisdictions may lack an information security management program for
electronic voting systems.
Develop and execute a security management plan that includes provisions
for
o conducting appropriate security training;
o ensuring that employees and contractors had proper certifications;
o defining security roles and responsibilities;
o performing audits according to a well-defined process;
o managing passwords effectively, especially on systems with hard-coded
passwords or weak password controls;
o controlling physical access to systems with weaknesses in their system
access controls; and
o controlling the use of personal computer memory cards and smart cards
for systems that did not protect such devices.
Controls for protecting cast o Redesign the voting system to
ballots, audit logs, ballot provide encryption for these
components.
definition files, and other vital o Develop administrative procedures
data elements are weak. to tightly govern access to the
voting
terminals, smart cards, and computers
used to store accumulated votes and
other vital data.
System has network or modem o When using network or modem
connections that are connections, (1) encrypt
transmissions,
subject to external network attacks. (2) update with anti-virus
protection, and (3) develop
administrative
procedures to minimize the use of
such connections.
Power or poll-closing switches are o Apply a lockable protective seal
exposed and to cover such buttons.
vulnerable to accidental or o Redesign the voting system to make
intentional triggering. such functionality password
protected.
The voting system may contain o Redesign the system to include a
malicious code that voter-verified paper audit trail for
each vote
could corrupt votes. cast.
Source: GAO analysis of recent reports and studies.
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).1 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 guide2 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
1GAO, Federal Information System Controls Audit Manual, GAO/AIMD-12.19.6
(Washington, D.C.: January 1999).
2GAO, Information Security Risk Assessment: Practices of Leading
Organizations, GAO/AIMD-00-33 (Washington, D.C.: November 1999).
Page 78 GAO-05-956 Electronic Voting Systems
Appendix III Summary of Selected Guidance on Information Technology Security and
Reliability
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 Description
SP 800-12: An Introduction to Computer Explains important concepts, cost
considerations, and interrelationships of security controls. Security: The
NIST Handbook (October It is intended to help readers understand their
computer security needs and develop a sound 1995) approach to the
selection of appropriate management, operational, and technical controls.
SP 800-14: Generally Accepted Principles Describes 8 principles and 14
related practices related to information security. It is designed and
Practices for Securing Information to serve as a foundation that
management, internal auditors, users, system developers, and Technology
Systems (September 1996) 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.
SP 800-18: Guide for Developing Security Describes a guideline for federal
agencies to follow when developing the security plans that Plans for
Information Technology Systems document the managerial, technical, and
operational controls for information systems. It (December 1998) 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.
SP 800-23: Guidelines to Federal Organizations on Security Assurance and
Acquisition/Use of Tested/Evaluated Products (August 2000)
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.
Federal Information Technology Security Identifies five levels of
information technology security program effectiveness that measure
Assessment Framework (November 2000) 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.
Appendix III Summary of Selected Guidance on Information Technology Security and
Reliability
(Continued From Previous Page)
NIST Publication Description
SP 800-26: Security Self-Assessment Provides guidance on applying the
Federal Information Technology Security Assessment Guide for Information
Technology Systems Framework through a questionnaire containing specific
control objectives and suggested (November 2001) techniques against which
the security of information systems can be measured.
SP 800-27, Rev. A: Engineering Principles for Information Technology
Security (A Baseline for Achieving Security) (June 2004)
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.
SP 800-30: Risk Management Guide for Information Technology Systems (July
2002)
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.
SP 800-34: Contingency Planning Guide Provides instructions,
recommendations, and considerations for government organizations for
Information Technology Systems (June to consider when developing a plan
for recovery of information technology services following 2002) 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.
SP 800-37: Guide for the Security Certification and Accreditation of
Federal Information Systems (May 2004)
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.
SP 800-50: Building an Information Technology Security Awareness and
Training Program (October 2003)
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.
SP 800-53: Recommended Security Provides guidelines for selecting and
specifying security controls for federal information Controls for Federal
Information Systems systems. It describes a process for selecting and
specifying security controls for information (February 2005) 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.
SP 800-55: Security Metrics Guide for Provides guidance for the specific
development, selection, and implementation of system-Information
Technology Systems (July level metrics to be used to measure the
performance of information system security controls 2003) 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.
Appendix III Summary of Selected Guidance on Information Technology Security and
Reliability
(Continued From Previous Page)
NIST Publication Description
SP 800-61: Computer Security Incident Assists organizations in
establishing a computer security incident response capability and
Handling Guide (January 2004) 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.
SP 800-64, Revision 1: Security Presents a framework for incorporating
security across the life cycle of a system and Considerations in the
Information System describes a minimum set of security steps needed to
effectively incorporate security into a Development Life Cycle (June 2004)
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.
SP 800-70: Security Configuration Checklist Program for IT Products-
Guidance for Checklist Users and Developers (May 2005)
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.
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 practices3 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)(R).
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
3CERT Coordination Center, CERT(R) Security Improvement Modules (Carnegie
Mellon University, undated), h ttp://www.cert.org/security-improvement/.
Page 81 GAO-05-956 Electronic Voting Systems Appendix III Summary of
Selected Guidance on Information Technology Security and Reliability
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 site4 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,5 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
4 SANS, www.sans.org. 5SANS, www.sans.org /rr/.
Page 82 GAO-05-956 Electronic Voting Systems Appendix III Summary of
Selected Guidance on Information Technology Security and Reliability
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.
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
Goal: Goal:
Resolution Date Improve Improve TGDC 2005 Future
number approved Resolution security reliability priority VVSG VVSG
title
Certified
Software
05-04 07/09/04 for the o o not # #
National
Software
Reference prioritized
Library
03-05 01/19/05 Human Factors and Privacy of Voting - o 1,2
6
!
Systems at the Polling Place
08-05 01/19/05 Usability Guidance for Instructions, Ballot - o 2 # !
Design, and Error Messages
09-05 01/19/05 General Voting System Human Factors and o o 1,2 6 !
Privacy Considerations
12-05 01/19/05 Voter Verifiability I z - 1,2 6 V !
14-05 01/19/05 Commercial Off-the-Shelf Software z - 2# !
15-05 01/19/05 Software Distribution z o 1
16-05 01/19/05 Setup Validation { o 1
6
6
!
!
17-05 01/19/05 Testing (for Security) z o 2# !
18-05 01/19/05 Documentation (for Security) z o o z 2 2 # 6 V ! !
21-05 01/19/05 Multiple Representations of
Ballots
22-05 01/19/05 Federal Standards z -- 2 6 !
23-05 01/19/05 Common Ballot Format z - 3 6 V !
Specifications
24-05 01/19/05 Conformance Clause o o 1,2 6
!
25-05 01/19/05 Precise and Testable Requirements o z 2# !
Appendix IV Resolutions Related to Voting System Security and Reliability
(Continued From Previous Page)
Goal: Goal:
Resolution Date Improve Improve TGDC 2005 Future
number approved Resolution title security reliability priority VVSG VVSG
Uniform Testing
26-05 01/19/05 Methods and o o 2 # !
Procedures
27-05 01/19/05 Non-Conformant o o 2 # !
Voting Systems
Ensuring
29-05 01/19/05 Correctness of o o 2 # !
Software Code
Quality
30-05 01/19/05 Management z o 3 # !
Standards
Sharing
32-05 01/19/05 Information and 3 # #
De-Qualification
of z z
Voting Systems
33-05 01/19/05 Glossary and Voting o o 1,2 6 !
Model
35-05 01/19/05 Wireless z - 1 6 !
36-05 03/09/05 Consensus Standards o o not # !
prioritized
Voter-Verified
39-05 04/21/05 Paper Audit Trail o o not # #
Assignment
prioritized
Source: GAO analysis of NIST and TGDC data.
Key:
Columns 4 and 5
z Resolution specifically identifies the goal
o Resolution facilitates achievement of the goal
- Resolution is not essential to the goal
Columns 7 and 8
! Expected to be fully addressed in publication 6 Expected to be partially
addressed in publication Supports voter-verified paper audit trail
implementation # Not expected to be addressed in publication
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")
Appendix V Comments from the Election Assistance Commission
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 EAC 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.
2
Appendix V Comments from the Election Assistance Commission
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
3
Appendix V Comments from the Election Assistance Commission
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
4
Appendix V Comments from the Election Assistance Commission
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
"3". 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 cataloguing. 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.
5
Appendix V Comments from the Election Assistance Commission
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,
Gracia Hillman, Chair Paul DeGregorio, Vice Chairman
Ray Martinez, III Donetta Davidson
6
Appendix VI
Comments from the National Institute of Standards and Technology
Appendix VII
GAO Contacts and Staff Acknowledgments
David A. Powner, (202) 512-9286 or p [email protected]
GAO Contacts
Randolph C. Hite, (202) 512-3439 or h [email protected]
In addition to those named above, Mark Braza, Barbara Collier, William
Staff
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.
Bibliography
Reports and Studies that Include Concerns About the Security and/or
Reliability of Voting Systems
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.
[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).
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). 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).
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).
Bibliography
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).
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).
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). 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).
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).
http://www.reformcoalition.org/Ressources/CFD%20miami%20dade%20fina
l%20report.pdf (downloaded July 18, 2005).
[10] Jones, Douglas W. Comments on the FEC's Draft Voting System Standards
as revised, Dec 13, 2001 (Submitted to the Federal Election Commission,
Jan. 2002). http://www.cs.uiowa.edu/~jones/voting/fec1.html (downloaded
June 3, 2005).
[11] Jones, Douglas W. Added Comments on the FEC's Voting System Standards
(Submitted to the Federal Election Commission, Feb. 2002).
http://www.cs.uiowa.edu/~jones/voting/fec2.html (downloaded June 3, 2005).
Bibliography
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