UNITED STATES E LECTION ASSISTANCE COMMISSION 2015 Voluntary Voting System Guidelines Volume 1 o Version 1 1 www eac gov Voluntary Voting System Guidelines Version 1 1 Table of Contents Volume I Voting System Performance Guidelines Overview Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 Voluntary Voting System Guidelines Overview Voting System Performance Guidelines Introduction Functional Requirements Usability and Accessibility Requirements Hardware Requirements Software Requirements Telecommunications Requirements Security Requirements Quality Assurance and Configuration Management Appendix A Appendix B Glossary References Volume II National Certification Testing Guidelines Section 1 Section 2 Section 3 Section 4 Section 5 Section 6 Section 7 Section 8 National Certification Testing Guidelines Introduction Quality and Configuration Management Manual Description of the Technical Data Package Functionality Testing Hardware Testing Software Testing System Integration Testing Quality Assurance and Configuration Management Appendix A Appendix B Appendix C National Certification Test Plan National Certification Test Report Assessing Conformity to Benchmarks Voluntary Voting System Guidelines Overview Guide to Section Locations Section 1 Introduction Section 2 Functional Requirements Section 3 Usability Accessibility and Privacy Requirements Section 4 Hardware Requirements Section 5 Software Requirements Section 6 Telecommunications Requirements Section 7 Security Requirements Section 8 Quality Assurance and Configuration Management Appendix A Glossary Appendix B References ii 2 14 42 78 101 117 124 153 A-1 B-1 VOLUNTARY VOTING SYSTEM GUIDELINES Volume I Voting System Performance Guidelines iV Voting System Performance Guidelines 1 Introduction Voluntary Voting System Guidelines Overview The United States Congress passed the Help America Vote Act of 2002 HAVA to modernize the administration of federal elections marking the first time in our nation's history that the federal government has funded an election reform effort HAVA provides federal funding to help the states meet the law's uniform and non-discretionary administrative requirements which include the following new programs and procedures 1 provisional voting 2 voting information 3 statewide voter registration lists and identification requirements for first-time registrants 4 administrative complaint procedures and 5 updated and upgraded voting equipment HAVA also established the U S Election Assistance Commission EAC to administer the federal funding and to provide guidance to the states in their efforts to comply with the HAVA administrative requirements Section 202 directs the EAC to adopt voluntary voting system guidelines and to provide for the testing certification decertification and recertification of voting system hardware and software The purpose of the guidelines is to provide a set of specifications and requirements against which voting systems can be tested to determine if they provide all the basic functionality accessibility and security capabilities required of voting systems This document the Voluntary Voting System Guidelines referred to herein as the Guidelines and or VVSG is the third iteration of national level voting system standards that has been developed The Federal Election Commission published the Performance and Test Standards for Punchcard Marksense and Direct Recording Electronic Voting Systems in 1990 This was followed by the Voting Systems Standards in 2002 Version 1 0 of the VVSG was adopted by a vote of EAC on December 13 2005 Version 1 1 of the VVSG was created by the EAC in an effort to update and improve version 1 0 of the VVSG Specifically Version 1 1 provides updates to requirements in the areas of security reliability usability and accessibility These improvements enhance the testability and clarity of several of the requirements contained in version 1 0 of the VVSG Purpose and Scope of the Guidelines The purpose of the Voluntary Voting System Guidelines is to provide a set of specifications and requirements against which voting systems can be tested to determine if they provide all the basic functionality accessibility and security capabilities required to ensure the integrity of voting systems The VVSG specifies the functional requirements performance characteristics documentation requirements and test evaluation criteria for the national certification of voting systems The VVSG is composed of two volumes Volume I Voting System Performance Guidelines and Volume II National Certification Testing Guidelines v Voting System Performance Guidelines 1 Introduction Effective Date The Voluntary Voting System Guidelines Version 1 1 will take effect after their final adoption by the EAC At that time there will be a transition period to move from the 2005 VVSG to VVSG 1 1 At a date to be determined by EAC Commissioners EAC will fully transition to VVSG 1 1 and manufacturers will no longer be able to test to the 2005 VVSG for a full system certification Modifications to a system qualified or certified to the 2005 VVSG after this date will be tested against the 2005 VVSG This VVSG effective date provision has no effect on the mandatory voting system requirements prescribed in HAVA Section 301 a which states must comply with on or before January 1 2006 The EAC issued Advisory 2005-004 to assist states in determining if a voting system is compliant with Section 301 a This advisory is available on the EAC website at www eac gov Volume I Voting System Performance Guidelines Summary Volume I the Voting System Performance Guidelines describes the requirements for the electronic components of voting systems It is intended for use by the broadest audience including voting system developers manufacturers and suppliers voting system testing labs VSTL state organizations that certify systems prior to procurement state and local election officials who procure and deploy voting systems and public interest organizations that have an interest in voting systems and voting system standards It contains the following sections Section I describes the purpose and scope of the Voting System Performance Guidelines Section 2 describes the functional capabilities required of voting systems This section has been revised to reflect HAVA Section 301 requirements Section 3 describes new standards that make voting systems more usable and accessible for as many eligible citizens as possible whatever their physical abilities language skills or experience with technology This section reflects the HAVA 301 a 3 accessibility requirements Sections 4 through 6 describe specific performance standards for election system hardware software telecommunications and security Environmental criteria have been updated in Section 4 Section 7 describes voting system security requirements and includes new requirements for voting system software distribution generation of software reference information validation of software during system setup and the use of wireless It also includes requirements for voter verifiable paper audit trail components for directrecording electronic voting systems vi Voting System Performance Guidelines 1 Introduction Section 8 describes requirements for manufacturer quality assurance and configuration management practices and the documentation about these practices required for the EAC certification process Appendix A contains a glossary of terms Appendix B provides a list of related standards documents incorporated into the Guidelines by reference documents used in the preparation of the Guidelines and referenced legislation Volume II National Certification Testing Guidelines Summary Volume II the National Certification Testing Guidelines is a complementary document to Volume I Volume II provides an overview and specific detail of the national certification testing process which is performed by independent voting system test labs VSTL accredited by the EAC It is intended principally for use by manufacturers VSTLs and election officials who certify procure and accept voting systems This volume contains the following sections Guide to Section Locations Section 1 describes the purpose of the National Certification Testing Guidelines Section 2 provides a description of the Quality and Configuration management manual that manufacturers are required to submit with their system for certification testing Section 3 provides a description of the Technical Data Package that manufacturers are required to submit with their system for certification testing Section 4 describes the basic functionality testing requirements Sections 5 through 7 define the requirements for hardware software and system integration testing Section 8 describes the required examination of manufacturer quality assurance and configuration management practices Appendix A provides the requirements for the National Certification Test Plan that is prepared by the VSTL and provided to the EAC for review Appendix B describes the scope and content of the National Certification Test Report which is prepared by the VSTL and delivered to the EAC along with a recommendation for certification vii Voting System Performance Guidelines 1 Introduction Appendix C describes a test method that is usable for assessing conformity to the requirements on accuracy misfeed rate and reliability analysis viii 1 Introduction Table of Contents 1 1 1 1 2 1 3 1 3 1 1 3 2 1 3 3 1 3 4 1 3 5 1 4 1 4 1 1 4 2 1 5 1 5 1 1 5 2 Introduction Purpose and scope of the Voluntary Voting System Guidelines Use of the Voluntary Voting System Guidelines Evolution of Voting System Standards Federal Election Commission Election Assistance Commission The EAC's Voting System Testing and Certification Program State Certification Testing Acceptance Testing Definitions References and Types of Voting Systems Definitions and References Types of Voting Systems Conformance Clause Structure of Requirements Implementation Statement 2 2 2 3 3 3 4 5 6 6 6 6 9 9 11 Voting System Performance Guidelines 1 Introduction 1 Introduction 1 1 Purpose and scope of the Voluntary Voting System Guidelines The purpose of the Voting System Performance Guidelines is to provide a set of specifications and requirements against which voting systems can be tested to determine if they provide all the basic functionality accessibility and security capabilities required of voting systems The performance guidelines specify the functional requirements performance characteristics documentation requirements and test evaluation criteria for the national certification of voting systems To the extent possible these requirements and specifications are described so they can be assessed by a series of defined objective tests Except as noted below Volume I of the Guidelines applies to all system hardware software telecommunications and documentation intended for use to o o o o o o o Prepare the voting system for use in an election Produce the appropriate ballot formats Test that the voting system and ballot materials have been properly prepared and are ready for use Record and count votes Consolidate and report election results Display results on-site or remotely Produce and maintain comprehensive audit trail data Some voting systems use one or more commercial off-the-shelf COTS devices such as card readers printers and personal computers or software products such as operating systems programming language compilers and database management systems These devices and products are exempt from certain portions of system certification testing as long as they are not modified for use in the voting system 1 2 Use of the Voluntary Voting System Guidelines The Guidelines are intended for use by multiple audiences to support their respective roles in the development testing and acquisition of voting systems o The accredited testing laboratories who use this information to develop test plans and procedures for the analysis and testing of systems in support of the national certification testing process o State and local election officials who are evaluating voting systems for potential use in their jurisdictions 2 Voting System Performance Guidelines 1 Introduction o Voting system designers and manufacturers who need to ensure that their products fulfill all these requirements so they can be certified 1 3 1 3 1 Evolution of Voting System Standards Federal Election Commission The first voting system standards were issued in January 1990 by the Federal Election Commission FEC This document included performance standards and testing procedures for Punchcard Marksense and Direct-Recording Electronic DRE voting systems These standards did not cover paper ballot and mechanical lever systems because paper ballots are sufficiently self-explanatory not to require technical standards and mechanical lever systems are no longer manufactured or sold in the United States The FEC also did not incorporate requirements for mainframe computer hardware because it was reasonable to assume that sufficient engineering and performance criteria already governed the operation of mainframe computers However vote tally software installed on mainframes was covered A national testing effort was initiated by NASED in 1994 As the system qualification process matured and qualified systems were used in the field the NASED Voting Systems Board in consultation with the testing labs identified certain testing issues that needed to be resolved Moreover rapid advancements in information and personal computer technologies introduced new voting system development and implementation scenarios not contemplated by the 1990 Standards In 1997 NASED briefed the FEC on the importance of keeping the Standards up to date Following a requirements analysis completed in 1999 the FEC initiated an effort to revise the 1990 Standards to reflect the evolving needs of the elections community This resulted in the 2002 Voting Systems Standards Voters and election officials who use voting systems represent a broad spectrum of the population and include individuals with disabilities who may have difficulty using traditional voting systems In developing accessibility provisions for the 2002 Voting System Standards the FEC requested assistance from the Access Board the federal agency in the forefront of promulgating accessibility provisions The Access Board submitted technical standards to meet the diverse needs of voters with a broad range of disabilities The FEC adopted the entirety of the Access Board's recommendations and incorporated them into the 2002 Voting Systems Standards 1 3 2 Election Assistance Commission In 2002 Congress passed the Help America Vote Act which established the U S Election Assistance Commission EAC EAC was mandated to develop and adopt new voluntary voting system guidelines and to provide for the testing certification and 3 Voting System Performance Guidelines 1 Introduction decertification of voting systems HAVA also established the Technical Guidelines Development Committee TGDC with the duty of assisting the EAC in the development of the new guidelines The Director of NIST chairs the TGDC and NIST was tasked to provide technical support to their work 1 3 3 The EAC's Voting System Testing and Certification Program The purpose of the Voting System Testing and Certification Program is to validate and document through an independent testing process that voting systems meet the requirements set forth in VVSG Volume 1 - Voting System Performance Guidelines and perform according to the manufacturer's specifications for the system Volume 1 specifies the minimum functional requirements performance characteristics documentation requirements and test evaluation criteria that voting systems must meet in order to receive national certification At this time 47 states either require national certification or utilize the national standards when certifying voting systems The EAC's Testing and Certification Program Manual documents the procedural requirements for this program Certification Testing under the EAC's program can only be performed by EAC accredited Voting System Test Labs VSTLs These VSTLs have been accredited for demonstrated technical competence to test voting systems using the Guidelines Volume 2 of the VVSG - National Testing and Certification Guidelines - provides guidance on the testing process and describes the associated documentation requirements These tests encompass the examination of software the inspection and evaluation of system documentation tests of hardware under conditions simulating the intended storage operation transportation and maintenance environments operational tests to validate system performance and function under normal and abnormal conditions and examination of the manufacturer's system development testing quality assurance and configuration management practices Certification tests address individual system components or elements as well as the integrated system as a whole The EAC's Voting System Test Laboratory Program Manual sets out the procedures for the accreditation of testing laboratories Since 1994 testing of voting systems was performed by Independent Test Authorities ITAs certified by NASED Upon the successful completion of testing the ITA issued a Qualification Test Report to the manufacturer and NASED The Technical Committee of the NASED Voting Systems Board would review the test report and if satisfactory issue a Qualification Number The Qualification Number remains valid for as long as the voting system remains unchanged HAVA mandated that the certification testing process be transferred from NASED to EAC National certification testing complements and evaluates the manufacturer's developmental testing and beta testing The VSTL is expected to evaluate the completeness of the manufacturer's developmental test program including the sufficiency of manufacturer tests conducted to demonstrate compliance with the Guidelines as well as the system's performance specifications The VSTL undertakes sample testing of the 4 Voting System Performance Guidelines 1 Introduction manufacturer's test modules and also designs independent system-level tests to supplement and check those designed by the manufacturer Although some of the certification tests are based on those prescribed in the Military Standards in most cases the test conditions are less stringent reflecting commercial rather than military practice Upon review of test reports and a determination that satisfactory results were achieved that address the full scope of testing EAC will issue a certification number that indicates the system has successfully completed testing by a VSTL for compliance with the Guidelines The certification number applies to the system as a whole and does not apply to individual system components or untested configurations After a system has completed initial certification testing further examination of the system is required if modifications are made to hardware software or telecommunications including the installation of software on different hardware Manufacturers request review of modifications by the VSTL based on the nature and scope of changes made The VSTL will assess whether the modified system should be resubmitted for certification testing and the extent of testing to be conducted and then it will provide an appropriate recommendation to the EAC and the manufacturer 1 3 4 State Certification Testing State certification tests are performed by individual states with or without the assistance of outside consultants to o Confirm that the voting system presented is the same as the one certified under the Guidelines o Test for the proper implementation of state-specific requirements o Establish a baseline for future evaluations or tests of the system such as acceptance testing or state review after modifications have been made o Define acceptance tests State certification test scripts are not included in the Guidelines as they must be defined by the state with its laws election practices and needs in mind However it is recommended that they not duplicate the national certification tests but instead focus on functional tests and qualitative assessment to ensure that the system operates in a manner that is acceptable under state law If a voting system is modified after state certification is completed it is recommended that states reevaluate the system to determine if further certification testing is warranted Certification tests performed by individual states typically rely on information contained in documentation provided by the manufacturer for system design installation operations required facilities and supplies personnel support and other aspects of the voting system States and jurisdictions may define information and documentation requirements additional to those defined in the Guidelines By design the Guidelines do not address these additional requirements However national certification testing will address all the capabilities of a voting system stated by the manufacturer in the system 5 Voting System Performance Guidelines 1 Introduction documentation submitted with the testing application to the EAC including additional capabilities that are not required by the states 1 3 5 Acceptance Testing Acceptance tests are performed at the state or local jurisdiction level upon system delivery by the manufacturer to o Confirm that the system delivered is the specific system certified by EAC and when applicable certified by the state o Evaluate the degree to which delivered units conform to both the system characteristics specified in the procurement documentation and those demonstrated in the national and state certification tests o Establish a baseline for any future required audits of the system Some of the operational tests conducted during certification may be repeated during acceptance testing 1 4 Definitions References and Types of Voting Systems 1 4 1 Definitions and References The Guidelines contain terms describing function design documentation and testing attributes of voting system hardware software and telecommunications Unless otherwise specified the intended sense of technical terms is that which is commonly used by the information technology industry In some cases terminology is specific to elections or voting systems A glossary of terms is contained in Appendix A Non-technical terms not listed in Appendix A shall be interpreted according to their standard dictionary definitions There are a number of technical standards that are incorporated in the Guidelines by reference These are referred to by title in the body of the document The full citations for these publications are provided in Appendix B In addition this appendix includes other references that may be useful for understanding and interpretation 1 4 2 Types of Voting Systems HAVA Section 301 defines a voting system as the total combination of mechanical electromechanical or electronic equipment including the software firmware and documentation required to program control and support the equipment that is used to define ballots to cast and count votes to report or display election results and to maintain and produce any audit trail information In addition a voting system includes the practices and associated documentation used to identify system components and 6 Voting System Performance Guidelines 1 Introduction versions of such components to test the system during its development and maintenance to maintain records of system errors and defects to determine specific system changes made after initial certification and to make available any materials to the voter such as notices instructions forms or paper ballots Traditionally a voting system has been defined by the mechanism the system uses to cast votes and further categorized by the location where the system tabulates ballots In addition to defining a common set of requirements that apply to all voting systems the VVSG states requirements specific to a particular type of voting system where appropriate However the Guidelines recognize that as the industry develops new solutions and the technology continues to evolve the distinctions between voting system types may become blurred The fact that the VVSG refers to specific system types is not intended to stifle innovations that may be based on a more fluid understanding of system types However appropriate procedures must be in place to ensure new developments provide the necessary integrity and can be properly evaluated in the certification process Consequently manufacturers that submit a system that integrates components from more than one traditional system type or a system that includes components or technology not addressed in the Guidelines shall submit the results of all beta tests of the new system when applying for national certification Manufacturers shall also submit a proposed test plan to the EAC for use in national certification testing The Guidelines permit manufacturers to produce or utilize interoperable components of a voting system that are tested within the full voting system configuration The listing below summarizes the functional requirements that HAVA Section 301 mandates to assist voters While these requirements may be implemented in a different manner for different types of voting systems all types of voting systems must provide these capabilities o permit the voter to verify in a private and independent manner the vote selected by the voter on the ballot before the ballot is cast and counted o provide the voter with the opportunity in a private and independent manner to change the ballot or correct any error before the ballot is cast and counted o notify the voter if he or she has selected more than one candidate for a single office inform the voter of the effect of casting multiple votes for a single office and provide the voter an opportunity to correct the ballot before it is cast and counted o be accessible for individuals with disabilities in a manner that provides the same opportunity for access and participation including privacy and independence as for other voters o provide alternative language accessibility pursuant to Section 203 of the Voting Rights Act 1 4 2 1 Paper-Based Voting System A paper-based voting system records votes counts votes and produces a tabulation of the vote count from votes cast on paper cards or sheets A marksense also known as optical 7 Voting System Performance Guidelines 1 Introduction scan voting system allows a voter to record votes by making marks directly on the ballot usually in voting response locations Additionally a paper-based system may allow for the voter's selections to be indicated by marks made on a paper ballot by an electronic input device as long as such an input device does not independently record store or tabulate the voter selections 1 4 2 2 Direct-Recording Electronic Voting System A direct-recording electronic DRE voting system records votes by means of a ballot display provided with mechanical or electro-optical components that can be activated by the voter that processes data by means of a computer program and that records voting data and ballot images in memory components It produces a tabulation of the voting data stored in a removable memory component and as printed copy The system may also provide a means for transmitting individual ballots or vote totals to a central location for consolidating and reporting results from precincts at the central location 1 4 2 3 Public Network Direct-Recording Electronic Voting System A public network DRE voting system is an election system that uses electronic ballots and transmits vote data from the polling place to another location over a public network Vote data may be transmitted as individual ballots as they are cast periodically as batches of ballots throughout the Election Day or as one batch at the close of voting For purposes of the Guidelines public network DRE voting systems are considered a form of DRE voting system and are subject to the standards applicable to DRE voting systems However because transmitting vote data over public networks relies on equipment beyond the control of the election authority the system is subject to additional threats to system integrity and availability Therefore additional requirements are applied to provide appropriate security for data transmission The use of public networks for transmitting vote data must provide the same level of integrity as other forms of voting systems and must be accomplished in a manner that precludes three risks to the election process automated casting of fraudulent votes automated manipulation of vote counts and disruption of the voting process such that the system is unavailable to voters during the time period authorized for system use 1 4 2 4 Precinct Count Voting System A precinct count voting system is a voting system that tabulates ballots at the polling place These systems typically tabulate ballots as they are cast and print the results after the close of polling For DREs and some paper-based systems these systems provide electronic storage of the vote count and may transmit results to a central location over public telecommunication networks 8 Voting System Performance Guidelines 1 Introduction 1 4 2 5 Central Count Voting System A central count voting system is a voting system that tabulates ballots from multiple precincts at a central location Voted ballots are typically placed into secure storage at the polling place Stored ballots are transported or transmitted to a central counting location The system produces a printed report of the vote count and may produce a report stored on electronic media 1 5 Conformance Clause This section provides information and requirements relating to how manufacturers and VSTLs use this document to assess whether a voting system conforms to the VVSG 1 5 1 Structure of Requirements Each part of the VVSG is organized into sections that address topics of interest Sections typically begin with prose explaining the general purpose etc This is informative background to help understand the requirements Sections also contain requirements which are the hard and fast rules to be followed for conformance The VVSG carefully distinguish normative requirements from informative context by using normative keywords as defined below Each voting system requirement in Volume I is identified according to a hierarchical scheme in which higher-level requirements such as provide accessibility for visually impaired voters are supported by lower-level requirements e g provide an audiotactile interface Thus requirements are nested When the nesting hierarchy has reached four levels i e 1 1 1 1 further nested requirements are designated with lowercase letters then roman numerals Therefore all requirements are traceable by a distinct reference Some requirements are directly testable and some are not The latter tend to be higherlevel and are included because 1 they are testable indirectly insofar as their lower-level requirements are testable and 2 they often provide the structure and rationale for the lower-level requirements Satisfying the lower-level requirements will result in satisfying the higher-level requirement 1 5 1 1 Normative Language The following keywords are used to convey conformance requirements o Shall - indicates a mandatory requirement in order to conform Synonymous with is required to 9 Voting System Performance Guidelines 1 Introduction o Shall not is prohibited -indicates a mandatory requirement that indicates something that is not permitted allowed in order to conform o Should is encouraged - indicates an optional recommended action one that is particularly suitable without mentioning or excluding others Synonymous with is permitted and recommended o May - indicates an optional permissible action Synonymous with is permitted What is neither required nor prohibited by the language of the Guidelines is permitted Informative parts of this document include examples extended explanations and other matter that contain information necessary for proper understanding of the Guidelines and conformance to it Unless otherwise specified a list of examples should not be interpreted as excluding other possibilities that were not listed 1 5 1 2 Applicability The requirements prohibitions options and guidance specified in these guidelines apply to voting systems voting system manufacturers VSTLs and software repositories In general requirements for voting systems in these guidelines apply to all types of voting systems unless prefaced with explanatory narrative that applicability is limited to a specific type of system or device The term manufacturer imposes documentation or testing requirements for the manufacturer Other terms in these guidelines shall be construed as synonymous with manufacturer including vendor voting system designers and implementer The terms used to designate requirements and procedural guidelines for accredited national certification testing laboratories are indicated by referring to VSTL Voting System Test Lab Other terms in these guidelines shall be construed as synonymous with VSTL including accredited test labs and test labs The term repository will be used to designate requirements levied on the National Software Reference Library repository maintained at NIST or any other designated repository These Guidelines are voluntary in that each of the states can decide whether to require the voting systems used in their state to have a national certification States may decide to adopt these Guidelines in whole or in part at any time irrespective of the effective date In addition states may specify additional requirements that voting systems in their jurisdiction must meet The national certification program does not in any way pre-empt the ability of the states to have their own system certification process 1 5 1 3 Categorizing Requirements The Guidelines set forth a common set of requirements for national certification that apply to all types of electronic voting systems They also provide requirements that are applicable for particular circumstances such as alternative language capability or disability accessibility The requirements implementing the HAVA Section 301 a 10 Voting System Performance Guidelines 1 Introduction mandates except for disability accessibility must be met by all voting systems The alternative language capability mandated by Section 301 a 4 must be met by all systems intended for use in jurisdictions subject to Section 203 of the Voting Rights Act The Section 301 a 3 disability accessibility requirements must be met by all systems intended to fulfill the one per polling place disability equipped voting system provision of Section 301 a 3 B In addition the Guidelines categorize some requirements into related groups or classes of functionality to address equipment type ballot tabulation location and voting system component e g election management system voting machine Hence all of the requirements contained in the Guidelines do not apply to all elements of all voting systems For example requirements categorized as applying to DRE systems are not applicable to paper-based voting The requirements implementing disability accessibility are not required of all voting systems only by those systems the manufacturer designates as accessible voting systems Among the categories defined in the VVSG are two types of voting systems with respect to mechanisms to cast votes - paper-based voting systems and DRE voting systems Additionally voting systems are further categorized by the locations where ballots are tabulated - precinct count voting systems which tabulate ballots at the polling place and central count voting systems which tabulate ballots from multiple precincts at a central location The Guidelines define specific requirements for systems that fall within these four categories as well as various combinations of these categories When a device that is submitted for certification testing combines functions of more than one of the categories referred to in the Guidelines that device must comply with all of the requirements that would apply to either or both categories of devices For example an electronic vote-capture device that is capable of recording votes either on an optical scan paper ballot or in electronic memory must comply with the requirements for paper-based systems when a paper record is created and must comply with the requirements for DREs when electronic records are created 1 5 1 4 Extensions Extensions are additional functions features and or capabilities included in a voting system that are not required by the Guidelines To accommodate the needs of states that may impose additional requirements and to accommodate changes in technology these guidelines allow extensions For example the requirements for a voter verifiable paper audit trail feature will only be applied to those systems designated by the manufacturer as providing this feature The use of extensions shall not contradict nor cause the nonconformance of functionality required by the Guidelines 1 5 2 Implementation Statement The manufacturer shall provide an implementation statement with their application to the EAC for national certification testing 11 Voting System Performance Guidelines 1 Introduction An implementation statement documents the requirements that have been implemented by the voting system the optional features and capabilities supported by the voting system and any extensions i e additional functionality beyond what is defined in the VVSG that it implements An implementation statement may take the form of a checklist to be completed for each voting system submitted for conformity assessment It is used by VSTLs to identify the conformity assessment activities that are applicable a An implementation statement shall include i Full product identification of the voting system including version number or timestamp ii Separate identification of each device that is part of the voting system iii Version of VVSG to which conformity assessment is desired iv Voting variations supported see Volume I Section 2 1 7 2 v Device capacities and limits vi List of languages supported vii List of accessibility capabilities and viii Signed attestation that the foregoing accurately characterizes the system submitted for testing A keyboard mouse accessibility peripheral or printer connected to a programmed voting device as well as any optical drive hard drive or similar component installed within it are considered components of the voting device not separate devices Specified capacities and limits should include the limit if any on the length of a candidate name that the system can process and display without truncation and similar limits for any other text fields whose usable or practically usable sizes are bounded If the system provides a way to access the entirety of a long name even when it does not fit the width of the display and does not use any data structures that would force truncation such a limit might not apply 12 2 Functional Requirements Table of Contents 2 2 1 2 1 1 2 1 2 2 1 3 2 1 4 2 1 5 2 1 6 2 1 7 2 1 8 2 1 9 2 1 10 2 2 2 2 1 2 2 2 2 2 3 2 2 4 2 2 5 2 2 6 2 3 2 3 1 2 3 2 2 3 3 2 4 2 4 1 2 4 2 2 4 3 2 4 4 2 4 5 2 5 Functional Requirements Overall System Capabilities Security Accuracy Error Recovery Integrity System Audit Election Management System Vote Tabulating Program Ballot Counter Telecommunications Data Retention Pre-voting Capabilities Ballot Preparation Election Programming Ballot and Program Installation and Control Readiness Testing Verification at the Polling Place Verification at the Central Location Voting Capabilities Opening the Polls Activating the Ballot Casting a Ballot Post-Voting Capabilities Closing the Polls Consolidating Vote Data Producing Reports Electronic Reports Election Night Reporting Maintenance Transportation and Storage 13 14 15 15 15 16 17 17 22 22 23 23 24 25 25 28 28 29 30 30 30 31 32 33 35 35 36 36 37 40 40 Voting System Performance Guidelines 2 Functional Requirements 2 Functional Requirements This section contains requirements detailing the functional capabilities required of a voting system This section sets out precisely what a voting system is required to do In addition it sets forth the minimum actions a voting system must be able to perform to be eligible for certification For organizational purposes functional capabilities are categorized as follows by the phase of election activity in which they are required 2 1 Overall System Capabilities These functional capabilities apply throughout the election process They include security accuracy integrity system auditability election management system vote tabulation ballot counters telecommunications and data retention 2 2 Pre-voting Capabilities These functional capabilities are used to prepare the voting system for voting They include ballot preparation the preparation of election-specific software including firmware the production of ballots the installation of ballots and ballot counting software including firmware and system and equipment tests 2 3 Voting System Capabilities These functional capabilities include all operations conducted at the polling place by voters and officials including the generation of status messages 2 4 Post-voting Capabilities These functional capabilities apply after all votes have been cast They include closing the polling place obtaining reports by voting machine polling place and precinct obtaining consolidated reports and obtaining reports of audit trails 2 5 Maintenance Transportation and Storage Capabilities These capabilities are necessary to maintain transport and store voting system equipment In recognition of the diversity of voting systems the Guidelines apply specific requirements to specific technologies Some of the guidelines apply only if the system incorporates certain optional functions for example voting systems employing telecommunications to transmit voting data For each functional capability common requirements are specified Where necessary these are followed by requirements applicable to specific technologies i e paper-based or DRE or intended use i e central or precinct count 14 Voting System Performance Guidelines 2 Functional Requirements 2 1 Overall System Capabilities This section defines required functional capabilities that are system-wide in nature and not unique to pre-voting voting and post-voting operations All voting systems shall provide the following functional capabilities further outlined in this section 2 1 1 2 1 2 2 1 3 2 1 4 2 1 5 2 1 6 2 1 7 2 1 8 2 1 9 2 1 10 Security Accuracy Error Recovery Integrity System Audit Election Management System Vote Tabulating Program Ballot Counter Telecommunications Data Retention Technical standards for these capabilities are described in Sections 3 through 6 of the Voluntary Voting System Guidelines 2 1 1 Security System security is achieved through a combination of technical capabilities and sound administrative practices To ensure security all systems shall a Provide security access controls that limit or detect access to critical system components to guard against loss of system integrity availability confidentiality and accountability b Provide system functions that are executable only in the intended manner and order and only under the intended conditions c Use the system's control logic to prevent a system function from executing if any preconditions to the function have not been met d Provide safeguards in response to system failure to protect against tampering during system repair or interventions in system operations e Provide security provisions that are compatible with the procedures and administrative tasks involved in equipment preparation testing and operation f Incorporate a means of implementing a capability if access to a system function is to be restricted or controlled g Provide documentation of mandatory administrative procedures for effective system security 2 1 2 Accuracy Memory hardware such as semiconductor devices and magnetic storage media must be accurate The design of equipment in all voting systems shall provide for the highest 15 Voting System Performance Guidelines 2 Functional Requirements possible levels of protection against mechanical thermal and electromagnetic stresses that impact system accuracy Section 4 provides additional information on susceptibility requirements To ensure vote accuracy all systems shall a Record the election contests candidates and issues exactly as defined by election officials b Record the appropriate options for casting and recording votes c Record each vote precisely as indicated by the voter and produce an accurate report of all votes cast d Include control logic and data processing methods incorporating parity and check-sums or equivalent error detection and correction methods to demonstrate that the system has been designed for accuracy e Provide software that monitors the overall quality of data read-write and transfer quality status checking the number and types of errors that occur in any of the relevant operations on data and how they were corrected In addition DRE systems shall f As an additional means of ensuring accuracy in DRE systems voting devices shall record and retain redundant copies of the original ballot image A ballot image is an electronic record of all votes cast by the voter including undervotes The accuracy benchmark specified in Section 4 1 1 is intended to allow tolerance for unpreventable hardware-related errors that occur rarely and randomly as a result of physical phenomena It is not intended to allow tolerance of software faults that result in systematic miscounting of votes As was written in Section 7 1 1 of the 1990 VSS In this case no margin for error exists Therefore g In all systems voting system software firmware and hardwired logic shall maintain absolute correctness introduce no errors in the recording tabulating and reporting of votes 2 1 3 Error Recovery To recover from a non-catastrophic failure of a device or from any error or malfunction that is within the operator's ability to correct the system shall provide the following capabilities a Restoration of the device to the operating condition existing immediately prior to the error or failure without loss or corruption of voting data previously stored in the device b Resumption of normal operation following the correction of a failure in a memory component or in a data processing component including the central processing unit 16 Voting System Performance Guidelines 2 Functional Requirements c Recovery from any other external condition that causes equipment to become inoperable provided that catastrophic electrical or mechanical damage due to external phenomena has not occurred 2 1 4 Integrity Integrity measures ensure the physical stability and function of the vote recording and counting processes To ensure system integrity all systems shall a Protect against a single point of failure that would prevent further voting at the polling place b Protect against the interruption of electrical power c Protect against generated or induced electromagnetic radiation d Protect against ambient temperature and humidity fluctuations e Protect against the failure of any data input or storage device f Protect against any attempt at improper data entry or retrieval g Include built-in measurement self-test and diagnostic software and hardware for detecting and reporting the system's status and degree of operability In addition to the common requirements DRE systems shall h Maintain a record of each ballot cast using a process and storage location that differs from the main vote detection interpretation processing and reporting path i Provide a capability to retrieve ballot images in a form readable by humans 2 1 5 System Audit This subsection describes the context and purpose of voting system audits and sets forth specific functional requirements Election audit trails provide the supporting documentation for verifying the accuracy of reported election results They present a concrete indestructible archival record of all system activity related to the vote tally and are essential for public confidence in the accuracy of the tally for recounts and for evidence in the event of criminal or civil litigation These requirements are based on the premise that system-generated creation and maintenance of audit records reduces the chance of error associated with manually generated audit records Because most audit capability is automatic the system operator has less information to track and record and is less likely to make mistakes or omissions The subsections that follow present operational requirements critical to acceptable performance and reconstruction of an election Requirements for the content of audit records are described in Section 2 1 5 1 17 Voting System Performance Guidelines 2 Functional Requirements The requirements for all system types both precinct and central count are described in generic language Because the actual implementation of specific characteristics may vary from system to system it is the responsibility of the manufacturer to describe each system's characteristics in sufficient detail so that VSTLs and system users can evaluate the adequacy of the system's audit trail This description shall be incorporated in the System Operating Manual which is part of the Technical Data Package Documentation of items such as paper ballots delivered paper ballots collected administrative procedures for system security and maintenance performed on voting equipment are also part of the election audit trail but are not covered in these technical standards Useful guidance is provided by the FEC publication Innovations in Election Administration #10 Ballot Security and Accountability available on the EAC's website 2 1 5 1 Operational Requirements Audit records shall be prepared for all phases of election operations performed using devices controlled by the jurisdiction or its contractors These records rely upon automated audit data acquisition and machine-generated reports with manual input of some information These records shall address the ballot preparation and election definition phase system readiness tests and voting and ballot-counting operations The software shall activate the logging and reporting of audit data as described a Voting system equipment shall record activities through an event logging mechanism b Voting system equipment shall enable file integrity protection for stored log files as part of the default configuration c The voting system equipment logs shall not contain information that if published would violate ballot secrecy or voter privacy or that would compromise voting system security in any way d The voting system equipment shall log at a minimum the following data characteristics for each type of event 1 system ID 2 unique event ID and or type 3 timestamp 4 success or failure of event if applicable 5 User ID trigger the event if applicable 6 Resources requested if applicable i Timekeeping mechanisms shall generate time and date values ii The precision of the timekeeping mechanism shall be able to distinguish and properly order all audit records iii Timestamps shall include the date and time including hours minutes and seconds iv Timestamps shall comply with ISO 8601 and provide all four digits of the year and include the applicable time zone v Voting system equipment shall only allow administrators to set or adjust the clock vi Voting system equipment shall limit clock drift to a minimum of 1 minute within a 15 hour period after the clock is set e Voting system equipment shall log all events including abnormal events i Voting system equipment shall ensure that event logging cannot be disabled 18 Voting System Performance Guidelines 2 Functional Requirements f Voting system equipment shall implement default settings for secure log management activities including log generation transmission storage analysis and disposal g Voting system equipment shall log clearing of logs and log rotation h Voting systems shall store logs in a publicly documented log format such as XML or include a utility to export the logs into a publicly documented for offsystem viewing i The manufacturer shall ensure that voting system equipment is supplied with enough free storage to include at least twice the maximum log size event logs j Voting systems shall be capable of retaining event log data from previous elections k Voting system equipment shall only allow administrators to modify the log data retention settings including the actions to take when a log reaches its maximum retention l Voting system equipment shall be capable of rotating the event log data to manage log file growth m Voting system equipment shall restrict event log access to write or append-only for privileged logging processes and read-only for administrator's accounts or roles n Voting system equipment shall digitally sign and export event logs o Voting systems shall include an application or program to view analyze and search event logs p Voting system equipment shall halt voting system activities and create an alert if the logging system malfunctions or is disabled q Voting system equipment shall create an alert as the log reaches 80% capacity r Voting system equipment shall protect event log information from unauthorized access modification and deletion s If the voting system provides log archival capabilities it shall ensure the integrity and availability of the archived logs All voting systems shall meet the requirements for error messages t The voting system shall generate store and report to the user all error messages as they occur u All error messages requiring intervention by an operator or precinct official shall be displayed or printed clearly in easily understood language text or by means of other suitable visual indicators v When the voting system uses numerical error codes for trained technician maintenance or repair the text corresponding to the code shall be self-contained or affixed inside the voting machine This is intended to reduce inappropriate reactions to error conditions and to allow for ready and effective problem correction w All error messages for which correction impacts vote recording or vote processing shall be written in a manner that is understandable to an election official who possesses training on system use and operation but does not possess technical training on system servicing and repair x The message cue for all voting systems shall clearly state the action to be performed in the event that voter or operator response is required 19 Voting System Performance Guidelines 2 Functional Requirements y Voting system design shall ensure that erroneous responses will not lead to irreversible error z Nested error conditions shall be corrected in a controlled sequence such that voting system status shall be restored to the initial state existing before the first error occurred The Guidelines provide latitude in software design so that manufacturers can consider various user processing and reporting needs The jurisdiction may require some status and information messages to be displayed and reported in real-time Messages that do not require operator intervention may be stored in memory to be recovered after ballot processing has been completed aa The voting system shall display and report critical status messages using clear indicators or English language text The voting system need not display noncritical status messages at the time of occurrence Voting systems may display non-critical status messages i e those that do not require operator intervention by means of numerical codes for subsequent interpretation and reporting as unambiguous text bb Voting systems shall provide a capability for the status messages to become part of the real-time audit record cc The voting system shall provide a capability for a jurisdiction to designate critical status messages 2 1 5 2 Use of Multitasking Operating Systems 1 To ensure completeness and integrity of audit data for election software further requirements must be applied to voting devices that use multitasking operating systems including COTS operating systems capable of executing multiple application programs simultaneously These operating systems support both servers and workstations and include the many varieties of UNIX and Linux and those offered by Microsoft and Apple Election software including any COTS or other software applications used in the voting system running on these systems is vulnerable to unintended effects from other user sessions applications and utilities executing on the same platform at the same time as the election software Simultaneous processes of concern include unauthorized network connections unplanned user logins and unintended execution or termination of operating system processes An unauthorized network connection or unplanned user login can host unintended processes and user actions such as the termination of operating system audit the termination of election software processes or the deletion of election software audit and logging data The execution of an operating system process could be a full system scan at a time when that process would adversely affect the election software processes Operating system processes improperly terminated could be system audit or malicious code detection 1 The italicized text in Section 2 1 5 2 is based on EAC Decision on Request for Interpretation 2008-03 http www eac gov assets 1 Page EAC%20Decision%20on%20OS%20Configuration pdf 20 Voting System Performance Guidelines 2 Functional Requirements To counter these vulnerabilities three operating system protections are required on all multitasking operating systems a First authentication shall be configured on the local terminal e g display screen and keyboard and on all external connection devices e g network cards and ports This ensures that only authorized and identified users affect the system while election software is running b Second operating system audit shall be enabled for all session openings and closings for all connection openings and closings for all process executions and terminations and for the alteration or deletion of any memory or file object This ensures the accuracy and completeness of election data stored on the system It also ensures the existence of an audit record of any person or process altering or deleting system data or election data c Third the system shall be configured to execute only intended and necessary processes during the execution of election software d The system shall also be configured to halt election software processes upon the termination of any critical system process such as system audit during the execution of election software e The manufacturer may use whatever metrics it wishes to establish the correct configuration of multitasking operating systems To ensure that these metrics are complete and consistent with current best practices for operating system security the VSTL shall evaluate the configuration documentation provided by the manufacturer in order to determine completeness clarity and consistency with best practice checklist criteria f The VSTL shall provide additional information if any inconsistency exists with the checklist criteria This information must include any rationale supporting the contention that any inconsistencies with the checklist are either not applicable or have been mitigated In its review of the VSTL evaluation of the operating system s configuration the EAC will designate appropriate checklists from the National Vulnerability Database NVD System Content Automation Protocol SCAP checklist repository as the benchmark for appropriate settings g If the operating system configuration is at variance to the designated SCAP checklist a justification for the variance shall be requested It is recognized that in some cases variances may be justifiable for optimum security and functionality For a given system some requirements may appropriately be determined to be not applicable to a specific device e g ballot marking devices depending specifically how the design of a device is implemented and what features are included Those determinations will be decided on a case-by-case model by model revision by revision basis primarily by the VSTL and then presented to the EAC for approval 21 Voting System Performance Guidelines 2 Functional Requirements 2 1 6 Election Management System The Election Management System EMS is used to prepare ballots and programs for use in casting and counting votes and to consolidate report and display election results An EMS shall generate and maintain a database or one or more interactive databases that enables election officials or their designees to perform the following functions o Define political subdivision boundaries and multiple election districts as indicated in the system documentation o Identify contests candidates and issues o Define ballot formats and appropriate voting options o Generate ballots and election-specific programs for voting equipment o Install ballots and election-specific programs o Test that ballots and programs have been properly prepared and installed o Accumulate vote totals at multiple reporting levels as indicated in the system documentation o Generate the post-voting reports required by Subsection 2 4 o Process and produce audit reports of the data as indicated in Subsection 5 4 2 1 7 Vote Tabulating Program Each voting system shall have a vote tabulation program that will meet specific functional requirements 2 1 7 1 Functions The vote tabulating program software resident in each voting machine vote count server or other devices shall include all software modules required to a Monitor system status and generate machine-level audit reports b Accommodate device control functions performed by polling place officials and maintenance personnel c Register and accumulate votes d Accommodate variations in ballot counting logic 2 1 7 2 Voting Variations There are significant variations among state election laws with respect to permissible ballot contents voting options and the associated ballot counting logic The Technical Data Package accompanying the system shall specifically identify which of the following items can and cannot be supported by the voting system as well as how the voting system can implement the items supported o Closed primaries 22 Voting System Performance Guidelines 2 Functional Requirements o o o o o o o o o o o o o o Open primaries Partisan offices Non-partisan offices Write-in voting Primary presidential delegation nominations Ballot rotation Straight party voting Cross-party endorsement Split precincts Vote for N of M Recall issues with options Cumulative voting Ranked order voting Provisional or challenged ballots 2 1 8 Ballot Counter For all voting systems each piece of voting equipment that tabulates ballots shall provide a counter that a b c d Can be set to zero before any ballots are submitted for tally Records the number of ballots cast during a particular test cycle or election Increases the count only by the input of a ballot Prevents or disables the resetting of the counter by any person other than authorized persons at authorized points e Is visible to designated election officials 2 1 9 Telecommunications a For all voting systems that use telecommunications for the transmission of data during pre-voting voting or post-voting activities capabilities shall be provided that ensure data are transmitted with no alteration or unauthorized disclosure during transmission b Such transmissions shall not violate the privacy secrecy and integrity demands of the Guidelines Section 6 describes telecommunications standards that apply to at a minimum the following types of data transmissions Voter Authentication Coded information that confirms the identity of a voter for security purposes for a system that transmit votes individually over a public network 23 Voting System Performance Guidelines 2 Functional Requirements Ballot Definition Information that describes to voting equipment the content and appearance of the ballots to be used in an election Vote Transmission to Central Site For voting systems that transmit votes individually over a public network the transmission of a vote or votes to the county or contractor for consolidation with other vote data Vote Count Information representing the tabulation of votes at any one of several levels polling place precinct or central count List of Voters A listing of the individual voters who have cast ballots in a specific election 2 1 10 Data Retention a United States Code Title 42 Sections 1974 through 1974e state that election administrators shall preserve for 22 months all records and paper that came into their possession relating to an application registration payment of poll tax or other act requisite to voting This retention requirement applies to systems that will be used at any time for voting of candidates for federal offices e g Member of Congress United States Senator and or Presidential Elector b Therefore all voting systems shall provide for maintaining the integrity of voting and audit data during an election and for a period of at least 22 months thereafter Because the purpose of this law is to assist the federal government in discharging its law enforcement responsibilities in connection with civil rights and elections crimes its scope must be interpreted in keeping with that objective The appropriate state or local authority must preserve all records that may be relevant to the detection and prosecution of federal civil rights or election crimes for the 22-month federal retention period if the records were generated in connection with an election that was held in whole or in part to select federal candidates It is important to note that Section 1974 does not require that election officials generate any specific type or classification of election record However if a record is generated Section 1974 comes into force and the appropriate authority must retain the records for 22 months c For 22-month document retention the general rule is that all printed copy records produced by the election database and ballot processing systems shall be so labeled and archived d Regardless of system type all audit trail information spelled out in Subsection 5 4 shall be retained in its original format whether that is real-time logs generated by the system or manual logs maintained by election personnel The election audit trail includes not only in-process logs of election-night and subsequent processing of absentee or provisional ballots but also time logs of baseline ballot definition formats and system readiness and testing results 24 Voting System Performance Guidelines 2 Functional Requirements In many voting systems the source of election-specific data and ballot formats is a database or file In precinct count voting systems this data is used to program each machine establish ballot layout and generate tallying files It is not necessary to retain this information on electronic media if there is an official authenticated printed copy of all final database information However it is recommended that the state or local jurisdiction also retain electronic records of the aggregate data for each voting machine so that reconstruction of an election is possible without data re-entry The same requirement and recommendation applies to vote results generated by each precinct count voting machine 2 2 Pre-voting Capabilities This subsection defines capabilities required to support functions performed prior to the opening of polls All voting systems shall provide capabilities to support o o o o o o Ballot preparation Election programming Ballot and program installation and control Readiness testing Verification at the polling place Verification at the central counting place The standards also include requirements to ensure compatible interfaces with the ballot definition process and the reporting of election results 2 2 1 Ballot Preparation Ballot preparation is the process of using election databases to define the specific contests questions and related instructions to be contained in ballots and to produce all permissible ballot layouts Ballot preparation requirements include o General capabilities o Ballot formatting o Ballot production 2 2 1 1 General Capabilities All systems shall provide the general capabilities for ballot preparation All systems shall be capable of a Enabling the automatic formatting of ballots in accordance with the requirements for offices candidates and measures qualified to be placed on the ballot for each political subdivision and election district 25 Voting System Performance Guidelines 2 Functional Requirements b Collecting and maintaining the following data i Offices and their associated labels and instructions ii Candidate names and their associated labels iii Issues or measures and their associated text c Supporting the maximum number of potentially active voting positions as indicated in the system documentation d For a primary election generating ballots that segregate the choices in partisan contests by party affiliation e Generating ballots that contain identifying codes or marks uniquely associated with each format f Ensuring that vote response fields selection buttons or switches properly align with the specific candidate names and or issues printed on the ballot display ballot or ballots or separate ballot pages Paper-based voting systems shall also meet the following requirements applicable to the technology used g Enable voters to make selections by making a mark in areas designated for this purpose upon each ballot sheet h For marksense systems ensure that the timing marks align properly with the vote response fields 2 2 1 2 Ballot Formatting Ballot formatting is the process by which election officials or their designees use election databases and voting system software to define the specific contests and related instructions contained on the ballot and present them in a layout permitted by state law All voting systems shall provide a capability for a Creation of newly defined elections b Rapid and error-free definition of elections and their associated ballot layouts c Uniform allocation of space and fonts used for each office candidate and contest such that the voter perceives no active voting position to be preferred to any other d Simultaneous display of the maximum number of choices for a single contest as indicated by the manufacturer in the system documentation e Retention of previously defined formats for an election f Prevention of unauthorized modification of any ballot formats g Modification by authorized persons of a previously defined ballot format for use in a subsequent election 2 2 1 3 Ballot Production Ballot production is the process of converting ballot formats to a media ready for use in the physical ballot production or electronic presentation 26 Voting System Performance Guidelines 2 Functional Requirements The voting system shall provide a means of printing or otherwise generating a ballot display that can be installed in all voting equipment for which it is intended All voting systems shall provide the capabilities below a The electronic display or printed document on which the user views the ballot is capable of rendering an image of the ballot in any of the languages required by the Voting Rights Act of 1965 as amended b The electronic display or printed document on which the user views the ballot does not show any advertising or commercial logos of any kind whether public service commercial or political unless specifically provided for in state law Electronic displays shall not provide connection to such material through hyperlink c The ballot conforms to manufacturer specifications for type of paper stock weight size shape size and location of mark field used to record votes folding bleed-through and ink for printing if paper ballot documents or paper displays are part of the system Basic Test Methodology 2 d Voting systems shall be tested to validate their ability to format and display voter targeted messages in a form consistent with all covered languages Incorporate the accents and special characters for Spanish or other languages display translated text as an image etc e The VSTL shall also provide a statement in the test report that identifies the level to which the language testing was performed f When appropriate the VSTL shall insert a disclaimer in the report that the translation content was not validated and that jurisdictions need to validate the content and accuracy of all translations g For DREs basic functional testing of the ballot logic shall be repeated for at least one of the set of languages in each of the significant language groups where the manufacturer supports such language groups For the purpose of this test procedure the functional language groups are o o o o The default language English A secondary language using a Western European font usually Spanish Ideographic language such as Chinese or Korean Non-written languages requiring audio support h The ballot preparation process shall prompt for an audio ballot to associate with each alternate language provided i In addition a sample of audio ballots in each group should be checked with at least one audio set to confirm that the voter is presented the correct audio ballot for the language selected The check shall exercise full ballot logic and navigational choices including shortcuts to exit or skip candidates or races j Care shall be taken to assure that less used navigation paths are checked 2 The italicized text in Section 2 2 1 3 is based on EAC Decision on Request for Interpretation 2008-04 http www eac gov assets 1 Page EAC%20Decision%20on%20Supported%20Languages pdf 27 Voting System Performance Guidelines 2 Functional Requirements For mark sense paper ballots the additional functional tests may be waived if one of the following is true k The operational test deck contains all ballot styles including the alternate language ballots as separate styles l It can be demonstrated that the ballot layout is not altered due to a change in language choice i e all ballot coding and voting mark sense target locations are the same regardless of ballot choices Discussion While the voting system need not offer every language covered by Section 203 of the Voting Rights Act the system must be tested and shown to have the capability to present or display any of the covered languages noted above m Manufacturer documentation for marksense systems shall include specifications for ballot materials to ensure that vote selections are read from only a single ballot at a time without detection of marks from multiple ballots concurrently e g reading of bleed-through from other ballots 2 2 2 Election Programming Election programming is the process by which election officials or their designees use election databases and manufacturer system software to logically define the voter choices associated with the contents of the ballots All systems shall provide for the a Logical definition of the ballot including the definition of the number of allowable choices for each office and contest b Logical definition of political and administrative subdivisions where the list of candidates or contests varies between polling places c Exclusion of any contest on the ballot in which the voter is prohibited from casting a ballot because of place of residence or other such administrative or geographical criteria d Ability to select from a range of voting options to conform to the laws of the jurisdiction in which the system will be used e Generation of all required master and distributed copies of the voting program in conformance with the definition of the ballots for each voting device and polling place and for each tabulating device 2 2 3 Ballot and Program Installation and Control a All systems shall provide a means of installing ballots and programs on each piece of polling place or central count equipment in accordance with the ballot requirements of the election and the requirements of the jurisdiction in which the equipment will be used 28 Voting System Performance Guidelines 2 Functional Requirements All systems shall include the following at the time of ballot and program installation b A detailed work plan or other documentation providing a schedule and steps for the software and ballot installation which includes a table outlining the key dates events and deliverables c A capability for automatically verifying that the software has been properly selected and installed in the equipment or in programmable memory devices and for indicating errors d A capability for automatically validating that software correctly matches the ballot formats that it is intended to process for detecting errors and for immediately notifying an election official of detected errors 2 2 4 Readiness Testing Election personnel conduct voting equipment and voting system readiness tests prior to the start of an election to ensure that the voting system functions properly to confirm that voting equipment has been properly integrated and to obtain equipment status reports All voting systems shall provide the capabilities to a Verify that voting equipment and precinct count equipment is properly prepared for an election and collect data that verifies equipment readiness b Obtain status and data reports from each set of equipment c Verify the correct installation and interface of all voting equipment d Verify that hardware and software function correctly e Generate consolidated data reports at the polling place and higher jurisdictional levels f Segregate test data from actual voting data either procedurally or by hardware software features Resident test software external devices and special purpose test software connected to or installed in voting equipment to simulate operator and voter functions may be used for these tests provided that the following standards are met g These elements shall be capable of being tested separately and shall be proven to be reliable verification tools prior to their use h These elements shall be incapable of altering or introducing any residual effect on the intended operation of the voting device during any succeeding test and operational phase Paper-based systems shall i Support conversion testing that uses all potential ballot positions as active positions j Support conversion testing of ballots with active position density for systems without pre-designated ballot positions 29 Voting System Performance Guidelines 2 Functional Requirements 2 2 5 Verification at the Polling Place Election officials perform verification at the polling place to ensure that all voting systems and voting equipment function properly before and during an election All voting systems shall provide a formal record of the following in any media upon verification of the authenticity of the command source a b c d e The election's identification data The identification of all equipment units The identification of the polling place The identification of all ballot formats The contents of each active candidate register by office and of each active measure register at all storage locations showing that they contain only zeros f A list of all ballot fields that can be used to invoke special voting options g Other information needed to confirm the readiness of the equipment and to accommodate administrative reporting requirements To prepare voting devices to accept voted ballots all voting systems shall provide the capability to test each device prior to opening to verify that each is operating correctly At a minimum the tests shall include h Confirmation that there are no hardware or software failures i Confirmation that the device is ready to be activated for accepting votes If a precinct count system includes equipment for the consolidation of polling place data at one or more central counting locations it shall have means to verify the correct extraction of voting data from transportable memory devices or to verify the transmission of secure data over secure communication links 2 2 6 Verification at the Central Location Election officials perform verification at the central location to ensure that vote counting and vote consolidation equipment and software function properly before and after an election Upon verification of the authenticity of the command source any system used in a central count environment shall provide a printed record of the following a The election's identification data b The contents of each active candidate register by office and of each active measure register at all storage locations showing that they contain all zeros c Other information needed to ensure the readiness of the equipment and to accommodate administrative reporting requirements 2 3 Voting Capabilities All voting systems shall support 30 Voting System Performance Guidelines 2 Functional Requirements o Opening the polls o Casting a ballot Additionally all DRE systems shall support o Activating the ballot o Augmenting the election counter o Augmenting the life-cycle counter 2 3 1 Opening the Polls a All vote counters must be zeroed before polls are opened If a device has a nonzero counter or residual votes this is a failure to activate correctly and thus a device or system failure Therefore the device shall disable itself from use in the voting system and election officials shall be advised of the proper corrective action i The occurrence shall be recorded in the device audit log ii In addition a clear unambiguous warning that an attempt has been made to initiate an election with non-zero totals and that the device has been disabled from the system shall be documented and communicated to an election official Jurisdictions that allow early voting before the nominal election day should note that a distinction is made between the opening and closure of polls which can occur only once per election and the suspension and resumption of voting between days of early voting The open-polls operation which requires zeroed counters is performed only when early voting commences the resumption of voting that was suspended overnight does not require that counters be zeroed again b The other capabilities required for opening the polls are specific to individual voting system technologies At a minimum the systems shall provide the functional capabilities indicated in the following sections 2 3 1 1 Precinct Count Systems To allow voting devices to be activated for voting all precinct count systems shall provide a An internal test or diagnostic capability to verify that all of the polling place tests specified in Subsection 2 2 5 have been successfully completed b Automatic disabling of any device that has not been tested until it has been tested 31 Voting System Performance Guidelines 2 Functional Requirements 2 3 1 2 Paper-based System Requirements To facilitate opening the polls all paper-based systems shall include a A means of verifying that ballot marking devices are properly prepared and ready to use b A voting booth or similar facility in which the voter may mark the ballot in privacy c Secure receptacles for holding voted ballots In addition to the above requirements all paper-based precinct count equipment shall include a means of d Activating the ballot counting device e Verifying that the device has been correctly activated and is functioning properly f Identifying device failure and corrective action needed 2 3 1 3 DRE System Requirements To facilitate opening the polls all DRE systems shall include a A security seal a password or a data code recognition capability to prevent the inadvertent or unauthorized actuation of the poll-opening function b A means of enforcing the execution of steps in the proper sequence if more than one step is required c A means of verifying the system has been activated correctly d A means of identifying system failure and any corrective action needed 2 3 2 Activating the Ballot To activate the ballot all DRE systems and all electronically-assisted ballot markers EBMs shall a Enable election officials to control the content of the ballot presented to the voter whether presented in printed form or electronic display such that each voter is permitted to record votes only in contests in which that voter is authorized to vote b Enable the selection of the ballot that is appropriate to the party affiliation declared by the voter in a primary election c Activate all portions of the ballot upon which the voter is entitled to vote d Disable all portions of the ballot upon which the voter is not entitled to vote In addition all DRE systems shall e Allow each eligible voter to cast a ballot 32 Voting System Performance Guidelines 2 Functional Requirements f Prevent a voter from voting on a ballot to which he or she is not entitled g Prevent a voter from casting more than one ballot in the same election h Activate the casting of a ballot in a general election 2 3 3 Casting a Ballot Some required capabilities for casting a ballot are common to all systems Others are specific to individual voting technologies or intended use Systems must provide additional functional capabilities that enable accessibility to disabled voters as defined in Subsection 3 2 2 3 3 1 Common Requirements To facilitate casting a ballot all systems shall a Provide text that is at least 3 millimeters high and provide the capability to adjust or magnify the text to an apparent size of 6 3 millimeters b Protect the secrecy of the vote such that the system cannot reveal any information about how a particular voter voted except as otherwise required by individual state law c Record the selection and non-selection of individual vote choices for each contest and ballot measure d Record the voter's selection of candidates whose names do not appear on the ballot if permitted under state law and record as many write-in votes as the number of candidates the voter is allowed to select e In the event of a failure of the main power supply external to the voting system provide the capability for any voter who is voting at the time to complete casting a ballot allow for the successful shutdown of the voting system without loss or degradation of the voting and audit data and allow voters to resume voting once the voting system has reverted to back-up power f Provide the capability for voters to continue casting ballots in the event of a failure of a telecommunications connection within the polling place or between the polling place and any other location 2 3 3 2 Paper-based System Requirements All paper-based systems shall a Allow the voter to easily identify the voting field that is associated with each candidate or ballot measure response b Allow the voter to mark the ballot to register a vote c Allow either the voter or the appropriate election official to place the voted ballot into the ballot counting device for precinct count systems or into a secure receptacle for central count systems 33 Voting System Performance Guidelines 2 Functional Requirements d Protect the secrecy of the vote throughout the process In addition to the above requirements all paper-based precinct count systems shall e Provide feedback to the voter that identifies specific contests for which he or she has made no selection or fewer than the allowable number of selections e g undervotes f Notify the voter if he or she has made more than the allowable number of selections for any contest e g overvotes g Notify the voter before the ballot is cast and counted of the effect of making more than the allowable number of selections for a contest h Provide the voter opportunity to correct the ballot for either an undervote or overvote before the ballot is cast and counted 2 3 3 3 DRE and EBM System Requirements In addition to the above common requirements DRE and EBM systems shall a Prohibit the voter from accessing or viewing any information on the display screen that has not been authorized by election officials and preprogrammed into the voting system i e no potential for display of external information or linking to other information sources b Enable the voter to easily identify the selection button or switch or the active area of the ballot display that is associated with each candidate or ballot measure response c Allow the voter to select his or her preferences on the ballot in any legal number and combination d Indicate that a selection has been made or canceled e Indicate to the voter when no selection or an insufficient number of selections has been made for a contest e g undervotes f Notify the voter if he or she has made more than the allowable number of selections for any contest e g overvotes g Notify the voter before the ballot is cast or printed of the effect of making more than the allowable number of selections for a contest h Provide the voter opportunity to correct the ballot for either an undervote or overvote before the ballot is cast or printed i Notify the voter when the selection of candidates and measures is completed j Allow the voter before the ballot is cast or printed to review his or her choices and if the voter desires to delete or change his or her choices before the ballot is cast or printed k Prompt the voter to confirm the voter's choices before casting or printing his or her ballot l Ensure that the votes stored or printed accurately represent the actual votes cast m Protect the secrecy of the vote throughout the voting process 34 Voting System Performance Guidelines 2 Functional Requirements In addition DREs shall n Signify to the voter that casting the ballot is irrevocable and direct the voter to confirm the voter's intention to cast the ballot before it is cast o Notify the voter after the vote has been stored successfully that the ballot has been cast p Notify the voter that the ballot has not been cast successfully if it is not stored successfully including storage of the ballot image and provide clear instruction as to the steps the voter should take to cast his or her ballot should this event occur q Prevent modification of the voter's vote after the ballot is cast r Provide a capability to retrieve ballot images in a form readable by humans in accordance with the requirements of Subsections 2 1 2 f and 2 1 4 h and i s Increment the proper ballot position registers or counters t Prohibit access to voted ballots until after the close of polls u Provide the ability for election officials to submit test ballots for use in verifying the end-to-end integrity of the voting system v Isolate test ballots such that they are accounted for accurately in vote counts and are not reflected in official vote counts for specific candidates or measures 2 4 Post-Voting Capabilities All voting systems shall provide capabilities to accumulate and report results for the jurisdiction and to generate audit trails In addition precinct count voting systems must provide a means to close the polls including generating appropriate reports If the system provides the capability to broadcast results additional standards apply 2 4 1 Closing the Polls These requirements for closing the polls and locking voting systems against future voting are specific to precinct count systems The voting system shall provide the means for a Preventing the further casting of ballots once the polls have closed b Providing an internal test that verifies that the prescribed closing procedure has been followed and that the device status is normal c Incorporating a visible indication of system status d Producing a diagnostic test record that verifies the sequence of events and indicates that the extraction of voting data has been activated e Precluding the unauthorized reopening of the polls once the poll closing has been completed for that election 35 Voting System Performance Guidelines 2 Functional Requirements 2 4 2 Consolidating Vote Data All systems shall provide a means to consolidate vote data from all polling places and optionally from other sources such as absentee ballots provisional ballots and voted ballots requiring human review e g write-in votes 2 4 3 Producing Reports a All systems shall be able to create reports summarizing the vote data on multiple levels b All systems shall provide capabilities to i Support geographic reporting which requires the reporting of all results for each contest at the precinct level and additional jurisdiction levels ii Produce a printed report of the number of ballots counted by each tabulator iii Produce a printed report for each tabulator of the results of each contest that includes the votes cast for each selection the count of undervotes and the count of overvotes iv Produce a consolidated printed report of the results for each contest of all votes cast including the count of ballots from other sources supported by the system as specified by the manufacturer that includes the votes cast for each selection the count of undervotes and the count of overvotes v Be capable of producing a consolidated printed report of the combination of overvotes for any contest that is selected by an authorized official e g the number of overvotes in a given contest combining candidate A and candidate B combining candidate A and candidate C etc vi Produce all system audit information required in Subsection 5 4 in the form of printed reports or in electronic memory for printing centrally vii Prevent data from being altered or destroyed by report generation or by the transmission of results over telecommunications lines c For all systems there shall be a complete accounting of undervotes for N of M contests as well as races involving only one voting choice 3 In a vote for N contest where L votes are recorded and L N the undervotes N-L In a vote for 3 contest votes would be recorded as follows o A vote for no candidates 3 undervotes o A vote for 1 candidate 2 undervotes o A vote for 2 candidates 1 undervote d In addition all precinct count voting systems shall i Prevent the printing of reports and the unauthorized extraction of data prior to the official close of the polls 3 The italicized text in Section 2 4 3 is based on EAC Decision on Request for Interpretation 2007-06 http www eac gov assets 1 Page EAC%20Decision%20on%20Recording%20and%20Reporting%20Unde rvotes pdf 36 Voting System Performance Guidelines 2 Functional Requirements ii Provide a means to extract information from a transportable programmable memory device or data storage medium for vote consolidation iii Consolidate the data contained in each unit into a single report for the polling place when more than one voting machine or precinct tabulator is used iv Prevent data in transportable memory from being altered or destroyed by report generation or by the transmission of official results over telecommunications lines 2 4 4 Electronic Reports Electronic reports for voting systems are used to support audits Typically the electronic reports needed include vote counts counts of ballots recorded information that identifies the electronic record event logs and other records of important events or details of how the election was run on this device and election archive information The following requirements specify what information needs to be captured in electronic reports used to support voting system audits and how to protect the electronic reports from modification and verify their source and authenticity 2 4 4 1 Voting system Electronic Reports The following requirements apply to electronic reports produced by the voting system for any exchange of information between devices support of auditing procedures or reporting of final results a The voting system shall provide the capability to export electronic reports to files formatted in a non-restrictive publicly-available format b Manufacturers shall provide a specification describing how they have implemented the format with respect to the manufacturer's specific voting devices and data including such items as descriptions of elements attributes constraints extensions syntax and semantics of the format and definitions for data fields and schemas c The voting system shall provide the ability to produce printed forms of electronic reports d The printed forms of the electronic reports shall retain all required information as specified for each report type other than digital signatures e The printing of the electronic reports MAY be done from a different component of the voting system that produced the electronic report It shall be possible to print electronic reports produced by the central tabulator or EMS on a different device f Voting systems shall digitally sign electronic reports using NIST approved algorithms with security strength of at least 112 bits implemented within a FIPS 140-2 level 1 or higher validated cryptographic module operating in FIPS mode 37 Voting System Performance Guidelines 2 Functional Requirements 2 4 4 2 Tabulator electronic reports The following requirements apply to electronic reports produced by tabulators such as DREs and optical scanners for exchange of information between devices transmission of results to the EMS support of auditing procedures or reporting of intermediate election results a Each tabulator shall produce a Tabulator Summary Count report including the following information i Identifier of the tabulator i e serial number ii Time and date of summary record iii The following both in total and broken down by ballot style and precinct o Number of read ballots o Number of counted ballots o Number of rejected electronic CVRs and o For each N-of-M including 1-of-M or cumulative voting contest appearing in any ballot style handled by the tabulator Number of counted ballots that included that contest Vote totals for each non-write-in contest choice Number of write-in votes Number of overvotes and Number of undervotes o When ballots span more than one piece of media such as paper sheets for optical scanners number of read media b In producing the Tabulator Summary Count report the tabulator shall assume that no provisional or challenged ballots are included c The tabulator shall i Transmit the summary count report to the EMS with the other electronic reports ii Store the summary count report in the election archive if available and iii Store the summary count report in the voting systems event log Tabulators should produce a report of ballot images that includes d Time and date of creation of complete ballot image report and e Ballot images recorded in randomized order by the DRE for the election NIST Special Publication 800-90 Recommendation for Random Number Generation Using Deterministic Random Bit Generators specifies techniques for the generation of random numbers that can be used to randomize the order of ballot images in a cryptographically sound way For each voted ballot this includes i Ballot style and reporting context ii For each contest o The choice recorded including undervotes and write-ins and o Any information collected electronically about each write-in iii Information specifying whether the ballot is provisional type of provisional ballot and providing a unique identifier for the ballot Types of provisional ballots such as regular provisional extended hours provisional and regular extended hours are jurisdiction-dependent 38 Voting System Performance Guidelines 2 Functional Requirements f DREs shall produce a report of ballot images that includes i Time and date at poll closing and ii Ballot images recorded in randomized order by the DRE for the election NIST Special Publication 800-90 Recommendation for Random Number Generation Using Deterministic Random Bit Generators specifies techniques for the generation of random numbers that can be used to randomize the order of ballot images in a cryptographically sound way For each voted ballot this includes o Ballot style and reporting context o For each contest The choice recorded including undervotes and write-ins and Any information collected electronically about each write-in iii Information specifying whether the ballot is provisional type of provisional ballot and providing a unique identifier for the ballot Types of provisional ballots such as regular provisional extended hours provisional and regular extended hours are jurisdiction-dependent g Tabulators that produce the collection of ballot images report shall iv Transmit the collection of ballot images report to the EMS with the other electronic reports v Store the collection of ballot images report in the election archive if available and vi Store the collection of ballot images report in the voting systems event log h The tabulator shall digitally sign the event log transmit the signed event log to an EMS and retain a record of the transmission i The tabulator digital signature shall be generated using a NIST approved algorithm with security strength of at least 112 bits implemented within a FIPS 140-2 level 1 or higher validated cryptographic module operating in FIPS mode 2 4 4 3 EMS electronic reports The following requirements apply to the reports produced by an EMS EMSs include both DREs used as accumulators in the polling place called a Precinct EMS as well as EMSs used as jurisdiction-wide accumulators All of the requirements for tabulators apply to EMSs This section addresses additional requirements based on a EMSs role as an accumulator of ballot counts and vote totals a Each EMS shall produce a Tabulator Summary Count report including the following information i Identifiers for each tabulator contained in the summary ii For tabulators with public keys o The public key for each tabulator in the summary and o Signed tabulator summary count report iii Summary ballot counts and vote totals by tabulator precinct and polling place o Precinct totals include subtotals from each tabulator used in the precinct 39 Voting System Performance Guidelines 2 Functional Requirements b The EMS shall be capable of combining tabulator reports to protect voter privacy c The EMS shall produce a report for each precinct including i Each tabulator included in the precinct with its identifier ii Number of read ballots iii Number of counted ballots and iv For each N-of-M including 1-of-M or cumulative voting contest appearing in any ballot style handled by the tabulator o Number of counted ballots that included that contest o Vote totals for each non-write-in contest choice and o Number of write-in votes d The EMS shall produce a report showing the changes made to each contest based on the resolution of provisional ballots challenged ballots write-in choices and the date and time of the report e For each tabulator producing electronic reports the EMS shall verify the digital signature on the report is correct using the public key associated with the tabulator 2 4 5 Election Night Reporting Some voting systems offer the capability to make unofficial results available to external organizations such as the news media political party officials and others Although this capability is not required systems that make unofficial results available shall a Provide only aggregated results and not data from individual ballots b Provide no access path from unofficial electronic reports or files to the storage devices for official data c Clearly indicate on each report or file that the results it contains are unofficial 2 5 Maintenance Transportation and Storage a All systems shall be designed and manufactured to facilitate preventive and corrective maintenance conforming to the hardware standards described in Subsection 4 1 b All vote casting and tally equipment designated for storage between elections shall i Function without degradation in capabilities after transit to and from the place of use as demonstrated by meeting the performance standards described in Subsection 4 1 ii Function without degradation in capabilities after storage between elections as demonstrated by meeting the performance standards described in Subsection 4 1 40 3 Usability and Accessibility Requirements Table of Contents 3 3 1 3 1 1 3 1 2 3 1 3 3 2 3 2 1 3 2 2 3 2 3 3 2 4 3 2 5 3 2 6 3 2 7 3 2 8 3 3 3 3 1 3 3 2 3 3 3 3 3 4 3 3 5 3 3 6 3 3 7 3 3 8 3 3 9 3 3 10 Usability Accessibility and Privacy Requirements Overview Purpose Special terminology Interaction of usability and accessibility requirements General usability requirements General usability Functional capabilities Voter privacy Voter instructions plain language and information presentation Visual display characteristics Voter-interface interaction Alternative languages Usability for poll workers Accessibility requirements General accessibility Enhanced visual interfaces Audio-tactile interfaces Enhanced input and control characteristics Design for mobility aids Enhanced auditory interfaces Design in support of cognitive disabilities English proficiency Speech not required Summative Usability Report 41 42 42 42 43 43 44 45 45 49 51 54 57 59 60 63 64 65 67 70 71 74 74 75 75 75 3 Usability Accessibility and Privacy Requirements 3 1 Overview The importance of usability and accessibility in the design of voting systems has become increasingly apparent It is not sufficient that the internal operation of these voting systems be correct in addition voters and poll workers must be able to use them effectively There are some particular considerations for the design of usable and accessible voting systems o The voting task itself can be fairly complex the voter may have to navigate an electronic ballot choose multiple candidates in a single contest or decide on abstrusely worded referenda o Voting is performed infrequently so there is limited opportunity for voters and poll workers to gain familiarity with the process o Jurisdictions may change voting equipment thus obviating whatever familiarity the voter might have acquired o Usability and accessibility requirements include a broad range of factors including physical abilities language skills and technology experience 3 1 1 Purpose The challenge then is to provide a voting system that voters can use comfortably efficiently and with confidence that they have cast their votes correctly The requirements within this section are intended to serve that goal Three broad principles motivate this section a All eligible voters shall have access to the voting process without discrimination i The voting process shall be accessible to individuals with disabilities The voting process includes access to the polling place instructions on how to vote initiating the voting session making ballot selections review of the ballot final submission of the ballot and getting help when needed b Each cast ballot shall accurately capture the selections made by the voter i The ballot shall be presented to the voter in a manner that is clear and usable Voters should encounter no difficulty or confusion regarding the process for recording their selections c The voting process shall preserve the secrecy of the ballot i The voting process shall preclude anyone else from determining the content of a voter's ballot without the voter's cooperation If such a determination is made against the wishes of the voter then his or her privacy has been violated All the requirements in this section have the purpose of improving the quality of interaction between voters and voting systems 42 Note that these principles refer to the entire voting process The VVSG applies only to voting systems other aspects of the process such as administrative rules and procedures are outside the scope of the VVSG but are nonetheless crucial for the full achievement of the principles 3 1 2 Special terminology The following terms are used frequently in this chapter they are defined in Appendix A of Volume 1 o o o o o o o o o o o o Accessible Voting Station Acc-VS Alert time Audio-Tactile Interface ATI Common Industry Format CIF Completed system response time Direct Record Electronic DRE Electronically-assisted Ballot Marker EBM Initial system response time Precinct Count Optical Scanner PCOS Precinct Tabulator Summative Usability Testing Voter inactivity time 3 1 3 Interaction of usability and accessibility requirements All the requirements in Section 3 have the purpose of improving the quality of interaction between voters and voting systems Please note how Sections 3 2 and 3 3 work together o The requirements for general usability in Section 3 2 apply to ALL voting systems including the Acc-VS They cover the features that are applicable both to the general population and to voters with disabilities In particular note that both DREs and EBMs are classified as Acc-VS Requirements for any alternative languages required by state or federal law are also included under Section 3 2 o The requirements for accessibility in Section 3 3 cover only those features that are mandatory for the Acc-VS in addition to the general usability requirements For instance an audio tactile interface would be of interest mainly to those with vision or other reading disabilities but not to those who can use a visual interface Therefore to determine what usability features are required of the Acc-VS one must examine both Sections 3 2 and 3 3 The features of the Acc-VS may also assist those not usually described as having a disability e g voters with poor reading vision or somewhat limited dexterity 4 4 The italicized text in Section 3 1 3 is based on EAC Decision on Request for Interpretation 2007-01 http www eac gov assets 1 Page EAC%20Decision%20on%20Accessible%20Design pdf 43 3 2 General usability requirements a The voting process shall provide a high level of usability for voters b Accordingly voters shall be able to negotiate the process effectively efficiently and comfortably The goal is that the resulting ballot accurately reflects the intention of the voter The mandatory voting system standards mandated in HAVA Section 301 relate to the interaction between the voter and the voting system a Requirements --Each voting system used in an election for federal office shall meet the following requirements 1 In general -A Except as provided in subparagraph B the voting system including any lever voting system optical scanning voting system or direct recording electronic system shall-i Permit the voter to verify in a private and independent manner the votes selected by the voter on the ballot before the ballot is cast and counted ii Provide the voter with the opportunity in a private and independent manner to change the ballot or correct any error before the ballot is cast and counted including the opportunity to correct the error through the issuance of a replacement ballot if the voter was otherwise unable to change the ballot or correct any error and iii If the voter selects votes for more than one candidate for a single office I Notify the voter that the voter has selected more than one candidate for a single office on the ballot II Notify the voter before the ballot is cast and counted of the effect of casting multiple votes for the office and III Provide the voter with the opportunity to correct the ballot before the ballot is cast and counted B A state or jurisdiction that uses a paper ballot voting system a punch card voting system or a central count voting system including mail-in absentee ballots and mail-in ballots may meet the requirements of subparagraph A iii by i Establishing a voter education program specific to that voting system that notifies each voter of the effect of casting multiple votes for an office and 44 ii Providing the voter with instructions on how to correct the ballot before it is cast and counted including instructions on how to correct the error through the issuance of a replacement ballot if the voter was otherwise unable to change the ballot or correct any error C The voting system shall ensure that any notification required under this paragraph preserves the privacy of the voter and the confidentiality of the ballot The requirements of this section are intended to support these basic usability standards of HAVA 3 2 1 General usability a The voting system shall support voters in the task of effectively completing their ballots b The features of the voting system shall not contribute to the commission of voter error within the voting session 3 2 2 Functional capabilities The usability of the voting process is enhanced by the presence of certain functional capabilities These capabilities differ somewhat depending on whether or not the system presents an editable interface within which voters can easily change their votes typically an electronic screen or an interface in which voters must obtain a new ballot to make changes typically a manually-marked paper ballot a If the voter selects more than the allowable number of choices within a contest the voting system shall notify the voter of the effect of this action before the ballot is cast and counted Discussion In the case of manual systems this may be achieved through appropriately placed instructions This requirement has no force for electronic ballot interfaces since they prevent overvoting in the first place b The voting system shall allow the voter at the voter's choice to submit an undervoted ballot without correction c The voting system shall provide the voter the opportunity to correct the ballot for either an undervote or overvote before the ballot is cast and counted 45 Discussion In the case of manual systems this may be achieved through appropriately placed written instructions Some corrections may require the voter to obtain a new paper ballot from a poll worker Also note the requirements on precinct-count optical scanners in Section 3 2 2 2 below d If and only if the voter successfully casts or prints the ballot then the electronic ballot interface or PCOS system shall so notify the voter Discussion The purpose of this requirement is to provide feedback to voters to assure them that the voting session has been completed Note that either a false notification of success or a missing confirmation of actual success violates this requirement 3 2 2 1 Editable electronic ballot interfaces Voting systems such as DREs and EBMs present voters with an editable interface allowing them to easily change their votes prior to final casting of the ballot a The electronic ballot interface shall prevent voters from selecting more than the allowable number of choices for each contest Discussion This requirement does not specify exactly how the system must respond when a voter attempts to select an extra candidate For instance the system may prevent the selection and issue a warning or in the case of a single-choice contest simply change the vote b The electronic ballot interface shall provide feedback to the voter before final casting or printing of the ballot that identifies specific contests for which the voter has selected fewer than the allowable number of choices i e undervotes Discussion For electronic ballot interface systems no allowance is made for disabling this feature Also see the plain language requirement below on clarity of warnings 3 2 4c i c The electronic ballot interface shall provide the voter the opportunity to correct the ballot before it is cast or printed The electronic ballot interface shall allow the voter to make these corrections without assistance The corrections to be supported include modifying an undervote and changing a vote from one candidate to another d The electronic ballot interface shall allow the voter to change a vote within a contest before advancing to the next contest Discussion The point here is that voters using an editable interface should not have to wait for a final ballot review screen in order to change a vote 46 e The electronic ballot interface shall provide navigation controls that allow the voter to advance to the next contest or go back to the previous contest before completing a vote on the contest s currently being presented whether visually or aurally Discussion For example voters should not be forced to proceed sequentially through all the contests before going back to check their votes within a previous contest f If the voter takes the appropriate action to cast a ballot but the DRE does not accept and record it successfully including failure to store the ballot image then the DRE shall so notify the voter and provide clear instruction as to the steps the voter should take to cast the ballot Discussion If a DRE fails at the point of casting a ballot it must clearly indicate to the voter and to election officials responding to the failure whether or not the ballot was cast Otherwise election officials may be unable to provide substantial confirmation that the vote was or was not counted possibly resulting in disenfranchisement or the casting of more than one ballot by a single voter A device that freezes when the voter attempts to cast the ballot providing no evidence one way or the other whether the ballot was cast would violate this requirement g If the electronic ballot interface generates a paper record or some other durable human-readable record that can be the official ballot or determinative vote record then the voting system shall allow the voter to verify that record using the same access features used by the voter to vote the ballot Discussion While paper records generally provide a simple and effective means for technology-independent vote verification their use can present difficulties for voters who use large font high contrast alternative languages and other settings described in Section 3 2 The purpose of this requirement is to ensure that all voters have a similar opportunity for vote verification Note that this requirement addresses the special difficulties that may arise with the use of paper Verification is part of the voting process and all the other general requirements apply to verification in particular those dealing with dexterity e g 3 3 4 c blindness e g 3 3 3 e and poor vision issues e g 3 2 5 g This requirement allows the voter to use the same access features throughout the entire voting session It also does not preclude the voter from choosing a different access feature to verify the record See also requirement 3 3 1 e 47 3 2 2 2 Non-Editable ballot interfaces Non-Editable interfaces such as manually-marked paper ballots do not have the same flexibility as do editable interfaces Nonetheless certain features are required especially in the case of precinct-based optical scanners a The PCOS system shall be capable of providing feedback to the voter that identifies specific contests for which the voter has made more than the allowable number of votes i e overvotes b The PCOS system shall be capable of providing feedback to the voter that identifies specific contests for which the voter has made fewer than the allowable number of votes i e undervotes The system shall provide a means for an authorized election official to deactivate this capability entirely and by contest However if a ballot is submitted with all the contests on one side left blank notification to the voter is performed as described in requirement 3 2 2 2 c c The PCOS system shall be capable of notifying the voter that he or she has submitted a paper ballot that is blank on one or both sides The system shall provide a means for an authorized election official to deactivate this capability Discussion One purpose of this feature is to detect situations in which the voter might be unaware that the ballot is two-sided This feature is distinct from the ability to detect and warn about undervoting d If the PCOS system has notified the voter that a potential error condition such as an overvote undervote or blank ballot exists the system shall then allow the voter to correct the ballot or to submit it as is Discussion This requirement mandates that the system be capable of allowing either correction or immediate submission For instance a questionable paper ballot might be physically ejected for possible correction This requirement does not constrain the procedures that jurisdictions might adopt for handling such situations e g whether poll worker intervention is required e Paper-based precinct tabulators shall be able to identify a ballot containing marginal marks When such a ballot is detected the tabulator shall i Return the ballot to the voter ii Provide feedback to the voter that identifies the specific contests for which a marginal mark was detected and iii Allow the voter either to correct the ballot or to submit the ballot as is without correction at the voter's choice 48 Discussion Basically a marginal mark is one that according to the manufacturer specifications is neither clearly countable as a vote nor clearly countable as a non-vote The purpose of this requirement is to provide more certainty about the handling of poorly-marked ballots If a given candidate or option is clearly marked as chosen or left completely unmarked then there is no ambiguity to resolve However each manufacturer should define a gray area with respect to location darkness etc in which marks will be actively flagged as ambiguous f Software used to format optical scan ballots shall constrain the size and contrast of all target areas to conform to the following requirements i The target shall be no less than 3 mm across in any direction ii The contrast ratio between the target area boundaries and the surrounding space shall be no less than 10 1 Discussion For example this applies to the oval or box outline delineating the target area as well as the broken arrow designating the target area g If the voter takes the appropriate action to cast a ballot but the PCOS system does not accept and record it successfully including failure to read the ballot or to transport it into the ballot box the PCOS shall so notify the voter Discussion This requirement means that PCOS systems must detect and report electrical and mechanical failures within the system itself It does not require the detection of errors on the part of the voter 3 2 3 Voter privacy The voting process must preclude anyone else from determining the content of a voter's ballot without the voter's cooperation Privacy ensures that the voter can cast votes based solely on his or her own preferences without intimidation or inhibition 3 2 3 1 Privacy at the polls a The voting system shall prevent others from determining the contents of a ballot 49 Discussion The voting system itself provides no means by which others can determine how one has voted Of course voters could simply tell someone else for whom they voted but the system provides no evidence for such statements and therefore voters cannot be coerced into providing such evidence It is assumed that the system is deployed according to the installation instructions provided by the manufacturer Whether the configuration of the voting system protects privacy may well depend on proper setup b The voting system shall support ballot privacy during the voting session and ballot submission Discussion This requirement may involve different approaches for electronic and paper interfaces In both cases appropriate shielding of the voting station is important When a paper record with ballot information needs to be transported by the voter devices such as privacy sleeves may be necessary This requirement applies to all records with information on votes such as a vote verification record even if that record is not itself a ballot c During the voting session the audio interface of the voting system shall be audible only to the voter Discussion Voters who are hard of hearing but need to use an audio interface may also need to increase the volume of the audio Such situations require headphones with low sound leakage d The voting system shall issue all warnings in a way that preserves the privacy of the voter and the confidentiality of the ballot Discussion HAVA 301 a 1 C mandates that the voting system must notify the voter of an attempted overvote in a way that preserves the privacy of the voter and the confidentiality of the ballot This requirement generalizes that mandate e The voting system shall not issue a receipt to the voter that would provide proof to another of how the voter voted 3 2 3 2 No recording of alternative format usage When voters use non-typical ballot interfaces such as large print or alternative languages their anonymity may be vulnerable To the extent possible only the logical contents of their ballots should be recorded not the special formats in which they were rendered However in the case of paper ballots where the interface is the record some format information is unavoidably preserved 50 a No information shall be kept within an electronic cast voter record that identifies any alternative language feature s used by a voter b No information shall be kept within an electronic cast voter record that identifies any accessibility feature s used by a voter 3 2 4 Voter instructions plain language and information presentation The features specified in this section are intended to minimize cognitive difficulties for voters Voters should always be able to operate the voting system and understand the effect of their actions Note that the should requirements in this section must be adhered to unless there is strong justification provided for making an exception a The voting system shall provide instructions for all its valid operations Discussion If an operation is available to the voter it must be documented Examples include how to change a vote how to navigate among contests how to cast a straight party vote how to cast a write-in vote and how to adjust display and audio characteristics b The voting system shall provide a means for the voter to get help directly from the system at any time during the voting session Discussion The voter should always be able to get context-sensitive help from the system when needed The purpose is to minimize the need for assistance from the poll worker Electronic ballot interface systems may provide this with a distinctive help button In addition to context-sensitive help any voting system may provide written instructions that are separate from the ballot c Instructional material for the voter shall conform to norms and best practices for plain language Discussion Although part of general usability the use of plain language is also expected to assist voters with cognitive disabilities The plain language requirements apply to instructions that are inherent to the voting system or that are generated by default To the extent that instructions are determined by election officials designing the ballot they are beyond of the scope of this requirement For specific guidance on how to implement this requirement see Guidelines for Writing Clear Instructions and Messages for Voters and Poll Workers at http vote nist gov 032906PlainLanguageRpt pdf i Warnings and alerts issued by the voting system shall be distinguishable from other information and should clearly state 51 The nature of the problem Whether the voter has performed or attempted an invalid operation or whether the voting system itself has malfunctioned in some way and The set of responses available to the voter Discussion For instance Do you need more time Select 'Yes' or 'No' rather than System detects imminent timeout condition In case of an equipment failure the only action available to the voter might be to get assistance from a poll worker ii When an instruction is based on a condition the condition should be stated first and then the action to be performed Discussion For instance use In order to change your vote do X rather than Do X in order to change your vote iii The voting system should use familiar common words and avoid technical or specialized words that voters are not likely to understand Discussion For instance there are more contests on the other side rather than additional contests are presented on the reverse iv Each distinct instruction should be separated spatially from other instructions for visual or tactile interfaces and temporally for auditory interfaces Discussion This implies not burying several unrelated instructions in a single long paragraph v The voting system should issue instructions on the correct way to perform actions rather than telling voters what not to do Discussion For example Fill in the oval for your write-in vote to count rather than If the oval is not marked your write-in vote cannot be counted vi The system's instructions should address the voter directly rather than use passive voice constructions Discussion For example remove and retain this ballot stub rather than this ballot stub must be removed and retained by the voter vii The voting system should avoid the use of gender-based pronouns Discussion For example write in your choice directly on the ballot rather than write in his name directly on the ballot 52 d Consistent with election law the voting system shall support a process that does not introduce bias for or against any of the contest choices to be presented to the voter In both visual and aural formats the choices shall be presented in an equivalent manner Discussion Certain differences in presentation are mandated by state law such as the order in which candidates are listed and provisions for voting for write-in candidates However comparable characteristics such as font size or voice volume and speed must be the same for all choices e The voting system shall provide the capability to design a ballot with a high level of clarity and comprehensibility i The voting system should not visually present a single contest spread over two pages or two columns Discussion Such a visual separation poses the risk that the voter may perceive one contest as two or fail to see additional choices If a contest has a large number of candidates it may be infeasible to observe this guideline ii The ballot shall clearly indicate the maximum number of candidates for which one can vote within a single contest iii The relationship between the name of a candidate and the mechanism used to vote for that candidate shall be consistent throughout the ballot Discussion For example the response field where voters indicate their votes must not be located to the left of some candidates' names and to the right of others' iv The voting system should present instructions near to where they are needed Discussion For instance only general instructions should be grouped at the beginning of the ballot those pertaining to specific situations should be presented where and when needed f The use of color by the voting system shall agree with common conventions a green blue or white is used for general information or as a normal status indicator b amber or yellow is used to indicate warnings or a marginal status c red is used to indicate error conditions or a problem requiring immediate attention g When an icon is used to convey information indicate an action or prompt a response it shall be accompanied by a corresponding linguistic label Discussion While icons can be used for emphasis when communicating with the voter they must not be the sole means by which information is conveyed since there is no widely accepted iconic language and therefore not all voters may understand a given icon 53 3 2 5 Visual display characteristics The requirements of this section are designed to minimize perceptual difficulties for the voter Some of these requirements are designed to assist voters with poor reading vision These are voters who might have some difficulty in reading normal text but are not typically classified as having a visual disability and thus might not be inclined to use the Acc-VS a If the voting system uses an electronic display screen as the primary visual interface for the voter the display shall have the following characteristics i Flicker frequency NOT between 2 Hz and 55 Hz ii Minimum display brightness 130 cd m2 iii Minimum display darkroom 7x7 checkerboard contrast 150 1 iv Minimum display pixel pitch 85 pixels inch 0 3 mm pixel v Minimum display area 700 cm2 vi Antiglare screen surface that shows no distinct virtual image of a light source vii Minimum uniform diffuse ambient contrast ratio for 500 lx illuminance 10 1 Discussion Aside from usability concerns this requirement protects voters from having visually-induced seizures b Any aspect of the voting system voter interface that is adjustable by either the voter or poll worker including font size color contrast audio volume or rate of speech shall automatically reset to a standard default value upon completion of that voter's session For the Acc-VS with an electronic image display the aspects include synchronized audio video mode and non-manual input mode Discussion This ensures that the voting system presents the same initial appearance to every voter c If any aspect of a voting system is adjustable by either the voter or poll worker there shall be a mechanism to allow the voter to reset all such aspects to their default values while preserving the current votes Discussion The purpose is to allow a voter or poll worker who has adjusted the system into an undesirable state to reset all the aspects and begin again d For all text intended for voters or poll workers the voting system shall provide a font with the following characteristics i Height of capital letters at least 3 0 mm ii x-height of at least 70% of cap height iii Stroke width at least 0 35 mm e A voting system that uses an electronic image display shall be capable of showing all information in at least two font sizes i 3 0-4 0 mm cap height with a corresponding x-height at least 70% of the cap height and a minimum stroke width of 0 35 mm ii 6 3-9 0 mm cap height with a corresponding x-height at least 70% of the cap height and a minimum stroke width of 0 7 mm under control of the voter The 54 system shall allow the voter to adjust font size throughout the voting session while preserving the current votes Discussion While larger font sizes may assist most voters with poor vision certain disabilities such as tunnel vision are best addressed by smaller font sizes Larger font sizes may also assist voters with cognitive disabilities This requirement mandates the availability of at least two font sizes but additional choices including continuous variability are allowed f Text intended for the voter should be presented in a sans serif font Discussion In general sans serif fonts are easier to read on-screen they look reasonably good when their size is reduced and they tend to retain their visual appeal across different platforms g Voting systems using paper ballots or paper verification records shall provide features that assist in the reading of such ballots and records by voters with poor reading vision Discussion While this requirement may be satisfied by one of its subrequirements other innovative solutions are not precluded i The voting system may achieve legibility of paper records by supporting the printing of those records in at least two font sizes 3 0-4 0mm and 6 3-9 0mm Discussion Although the system may be capable of printing in several font sizes the use of various font sizes in an actual election may be governed by local or state laws and regulations ii The system may achieve legibility of paper records by supporting magnification of those records This magnification may be done by optical or electronic devices The manufacturer may either 1 provide the magnifier itself as part of the system or 2 provide the make and model number of readily available magnifiers that are compatible with the system Discussion The magnifier s either provided or cited must of course provide legibility for the paper as actually presented on the system For instance if the paper record is under a transparent cover to prevent the voter from touching it the means of magnification must be compatible with this configuration Straight edge magnifiers which allow the user to read an entire line may be especially suitable for the voting task h The colors in the default presentation shall support perception by voters and poll workers with color vision deficiencies of all text controls and infographics or icons on the ballot or ballot interface 55 Discussion There are many types of color vision deficiencies or color blindness and no color coding can by itself guarantee correct perception for everyone However designers should take into account such factors as redgreen color blindness is the most common form high luminosity contrast will help colorblind voters to recognize visual features and color-coded graphics can also use shape to improve the ability to distinguish certain features For specific guidance on how to implement this requirement please see NISTIR 7537 Guidelines for Using Color in Voting Systems at http www nist gov itl vote upload NISTIR-7537 pdf i The default visual display for voters and poll workers of a voting station with an electronic display shall have a luminosity contrast ratio between the foreground text and background color of at least 10 1 for all elements that visually convey information such as text controls and infographics or icons For paper ballots the contrast ratio shall be at least 10 1 as measured based on ambient lighting of at least 300 lx Discussion A 10 1 luminosity contrast ratio provides enough difference between the text and background to enable people with most color vision deficiencies to read the ballot Note that this is higher than the general web requirements of 4 5 1 in WCAG 2 0 Checkpoint 1 4 6 Level AAA to accommodate a wider range of visual disabilities There are several free tools available to test color luminosity contrast including http juicystudio com services luminositycontrastratio php ii A voting station with an electronic display screen shall have a high contrast mode either as an initial setting or under the control of the voter If the system allows the voter to adjust contrast during the voting session it shall preserve the current votes High contrast is a luminosity contrast ratio between the foreground text and background color of at least 20 1 The high contrast mode shall use at least one of the following color combinations o Black text on a white background o White text on a black background o Yellow text on a black background o Light cyan text on a black background Discussion A high contrast mode ensures that there is an option for the visual presentation for people with color vision deficiencies or whose vision requires high contrast i Color coding shall not be used as the sole means of conveying information indicating an action prompting a response or distinguishing a visual element 56 Discussion While color can be used for emphasis some other non-color mode must also be used This could include shape lines words text or text style For example an icon for stop can be red enclosed in an octagon shape Or a background color can be combined with a bounding rule and a label to group elements on the ballot 3 2 6 Voter-interface interaction The requirements of this section are designed to minimize interaction difficulties for the voter a The electronic ballot interface shall not require page scrolling by the voter Discussion That is the page of displayed information must fit completely within the physical screen presenting it Scrolling is not an intuitive operation for those unfamiliar with the use of computers Even those experienced with computers often do not notice a scroll bar and miss information at the bottom of the page Voting systems may require voters to move to the next or previous page b The voting system shall provide unambiguous feedback regarding the voter's selection such as displaying a checkmark beside the selected option or conspicuously changing its appearance c Voting system input mechanisms shall be designed to prevent accidental activation Discussion There are at least two kinds of accidental activation One is when a control is activated as it is being explored by the voter because the control is overly sensitive to the touch A second issue is the problem of having a control in a location where it can easily be activated unintentionally An example would be a button in the very bottom left corner of the screen where a voter might hold the unit for support i On touch screens the sensitive touch areas shall have a minimum height of 0 5 inches and minimum width of 0 7 inches The vertical distance between the centers of adjacent areas shall be at least 0 6 inches and the horizontal distance at least 0 8 inches Touch areas shall not overlap ii No key or control on a voting system shall have a repetitive effect as a result of being held in its active position Discussion This is to preclude accidental activation For instance if a voter is typing in the name of a write-in candidate depressing and holding the e key results in only a single e added to the name 57 3 2 6 1 Timing These requirements address how long the system and voter wait for each other to interact a The initial system response time of the electronic ballot interface shall be no greater than 0 5 seconds Discussion This is so the voter can very quickly perceive that an action has been detected by the system and is being processed The voter never gets the sense of dealing with an unresponsive or dead system Note that this requirement applies to auditory and visual voting system responses b When the voter performs an action to record a single vote the completed system response time of the electronic ballot interface shall be no greater than one second in the case of a visual response and no greater than five seconds in the case of an audio response Discussion For example if the voter touches a button to indicate a vote for a candidate a visual system might display an X next to the candidate's name and an audio system might announce You have voted for John Smith for Governor c The completed system response time during a voter interaction with the visual display of the electronic ballot interface shall be no greater than 10 seconds Discussion Even for large operations such as initializing the ballot or painting a new screen the system must never take more than 10 seconds In the case of audio systems no upper limit is specified since certain operations may take longer depending on the length of the text being read e g reading out a long list of candidates running in a contest d If the electronic ballot interface has not completed its visual response within one second it shall present to the voter within 0 5 seconds of the voter's action some indication that it is preparing its response Discussion For instance the system might present a progress bar indicating that it is busy processing the voter's request This requirement is intended to preclude the frozen screen effect in which no detectible activity is taking place for several seconds There need not be a specific activity icon as long as some visual change is apparent such as progressively painting a new screen e The electronic ballot interface shall detect and warn about lengthy voter inactivity during a voting session Each electronic ballot interface shall have a defined and documented voter inactivity time and that time shall be between two and five minutes 58 Discussion Each type of system must have a given inactivity time that is consistent among and within all voting sessions This ensures that all voters are treated equitably f Upon expiration of the voter inactivity time the electronic ballot interface shall issue an alert and provide a means by which the voter may receive additional time The alert time shall be between 20 and 45 seconds If the voter does not respond to the alert within the alert time the electronic ballot interface shall go into an inactive state requiring poll worker intervention 3 2 7 Alternative languages HAVA Section 301 a 4 states that the voting system shall provide alternative language accessibility pursuant to the requirements of Section 203 of the Voting Rights Act of 1965 42 U S C 1973aa-1a Ideally every voter would be able to vote independently and privately regardless of language As a practical matter alternative language access is mandated under the Voting Rights Act of 1975 subject to certain thresholds e g if the language group exceeds 5% of the voting age population Thus election officials must ensure that the voting system they deploy is capable of handling the languages meeting the legal threshold within their districts While the following requirements support this process it should be noted that they are requirements only for voting systems to be certified It is anticipated that jurisdictions will apply additional requirements appropriate for their particular circumstances for procurement and deployment a The voting system shall be capable of presenting the ballot contest choices review screens vote verification records and voting instructions in any language declared by the manufacturer to be supported by the system Discussion For example if the manufacturer claims that a given system is capable of supporting Spanish and Chinese then it must do so Presentation of the ballot includes both visual and audio formats Both written and unwritten languages are within the scope of this requirement 5 i The electronic ballot interface should allow the voter to select among the available languages throughout the voting session while preserving the current votes When presenting a choice of languages to the voter the electronic ballot interface shall use the native name of each language 5 The italicized text in Section 3 2 7 is based on EAC Decision on Request for Interpretation 2007-04 http www eac gov assets 1 Page EAC%20Decision%20on%20Presentation%20of%20Alternative%20Langua ge pdf See also 2009-02 http www eac gov assets 1 Page EAC Decision on Alternate Languages pdf 59 Discussion For instance a voter may initially choose an English version of the ballot but then wish to switch to another language in order to read a referendum question ii Information presented to the voter in the typical case of English-literate voters including instructions warnings messages contest choices and vote verification information shall also be presented when an alternative language is being used whether the language is written or an unwritten language presented aurally Discussion Therefore it may not be sufficient simply to present the ballot per se in the alternative language especially in the case of electronic ballot interface systems All the supporting information must also be available in the alternative language iii Any records including paper ballots and paper verification records shall have the information required to support auditing by poll workers and others who can read only English Discussion Even though the system must be easily available to voters without a command of English any persistent records of the vote must also be fully available to English-only readers for auditing purposes In the case of paper this does not imply a fully bi-lingual ballot For instance the full text of a referendum question might appear only in the alternative language but the content of the vote e g yes on ballot question 106 needs to be readable by English-only readers iv The manufacturer shall conduct summative usability tests for each of the voting system's supported languages using subjects who are fluent in those languages but not fluent in English and shall report the test results using the Common Industry Format as part of the TDP In addition the usability test report shall be submitted to the EAC as part of the documentation manufacturers are required to file with the application to test a voting system 3 2 8 Usability for poll workers Voting systems are used not only by voters to record their votes but also by poll workers who are responsible for set-up operation while polls are open light maintenance and poll closing Because of the wide variety of implementations it is impossible to specify detailed design requirements for these functions The requirements below describe general capabilities that all systems must support a Messages generated by the voting system for poll workers in support of the operation maintenance or safety of the system shall adhere to the requirements for 60 clarity in Section 3 2 4 Voter instructions plain language and information presentation 3 2 8 1 Operation Poll workers are responsible for opening polls keeping the polls open and running smoothly during voting hours and closing the polls afterwards Operations may be categorized in three phases Setup includes all the steps necessary to take the system from its state as normally delivered to the polling place to the state in which it is ready to record votes It does not include ballot definition Polling includes such functions as o o o o voter identification and authorization preparing the system for the next voter assistance to voters who wish to change their ballots or need other help system recovery in the case of voters who abandon the voting session without having cast a ballot and routine hardware operations such as installing a new roll of paper Shutdown includes all the steps necessary to take the system from the state in which it is ready to record votes to its normal completed state in which it has captured all the votes cast and the voting information cannot be further altered a Voting system setup polling and shutdown as documented by the manufacturer shall be reasonably easy for the typical poll worker to learn understand and perform Discussion This requirement covers procedures and operations for those aspects of system operation normally performed by poll workers and other non-expert operators It does not address inherently complex operations such as ballot definition or system repair While a certain amount of complexity is unavoidable these normal procedures should not require any special expertise The procedures may require a reasonable amount of training b The manufacturer shall conduct summative usability tests on the voting system using individuals who are representative of the general population and shall report the test results using the Common Industry Format as part of the TDP i The tasks to be covered in the test shall include setup operation and shutdown ii In addition the usability test report shall be submitted to the EAC as part of the documentation manufacturers are required to file with the application to test a voting system c The voting system shall include clear complete and detailed instructions and messages for setup polling and shutdown 61 Discussion This requirement covers documentation for those aspects of system operation normally performed by poll workers and other non-expert operators It does not address inherently complex operations such as ballot definition The instructions would usually be in the form of a written manual but could also be presented on other media such as a DVD or videotape In the context of this requirement message means information delivered by the system to the poll worker as he or she attempts to perform a setup polling or shutdown operation For specific guidance on how to implement this requirement please see NISTIR 7519 Style Guide for Voting System Documentation at http www nist gov itl vote upload NISTIR-7519 pdf i The documentation required for normal voting system operation shall be presented at a level appropriate for poll workers who are not experts in voting system and computer technology Discussion For instance the documentation should not presuppose familiarity with personal computers ii The documentation shall be in a format suitable for use in the polling place Discussion For instance a single large reference manual that simply presents details of all possible operations would be difficult to use unless accompanied by aids such as a simple how-to guide iii The instructions and messages shall enable the poll worker to verify that the voting system o Has been set up correctly setup o Is in correct working order to record votes polling and o Has been shut down correctly shutdown Discussion The poll worker should not have to guess whether an operation has been performed correctly The documentation should make it clear what the system looks like when correctly configured 3 2 8 2 Safety All voting systems and their components must be designed so as to eliminate hazards to personnel or to the equipment itself Hazards include but are not limited to o o o o fire hazards electrical hazards potential for equipment tip-over stability potential for cuts and scrapes e g sharp edges 62 o potential for pinching e g tight spring-loaded closures and o potential for hair or clothing entanglement a Devices associated with the voting system shall be certified in accordance with the requirements of UL 60950-1 Information Technology Equipment - Safety - Part 1 by a certification organization accredited by the Department of Labor Occupational Safety and Health Administration's Nationally Recognized Testing Laboratory program b The certification organization's scope of accreditation shall include IEC UL 609501 Discussion IEC UL 60950 is a comprehensive standard for IT equipment and addresses all the hazards discussed above under Safety 3 3 Accessibility requirements HAVA Section 301 a 3 HAVA02 reads in part ACCESSIBILITY FOR INDIVIDUALS WITH DISABILITIES --The voting system shall- A be accessible for individuals with disabilities including nonvisual accessibility for the blind and visually impaired in a manner that provides the same opportunity for access and participation including privacy and independence as for other voters B satisfy the requirement of subparagraph A through the use of at least one direct recording electronic voting system or other voting system equipped for individuals with disabilities at each polling place The voting process is to be accessible to voters with disabilities through the use of a specially equipped voting station A machine so equipped is referred to herein as an accessible voting station Acc-VS The requirements in this section are intended to address this HAVA mandate Ideally every voter would be able to vote independently and privately As a practical matter there may be some number of voters who because of the nature of their disabilities will need personal assistance with any system Nonetheless these requirements are meant to make the voting system independently accessible to as many voters as possible This includes access across all voting processes capabilities to generate verify and cast an official ballot must be provided This section is organized according to system features that accommodate a variety of disabilities A feature intended primarily to address a specific disability may very well assist voters with other types of disabilities Moreover this organization in no way implies that the various sets of requirements are optional or mutually exclusive In order to conform an AccVS must fulfill all the requirements of all the sub-sections of Chapter 3 3 63 There are many other requirements such as the general usability requirements that apply to the Acc-VS besides those in this section Please see Section 3 1 3 Interaction of usability and accessibility requirements for a full explanation 3 3 1 General accessibility The requirements 6 of this section are relevant to a wide variety of disabilities a The Acc-VS shall be integrated into the manufacturer's complete voting system so as to support accessibility for disabled voters throughout the voting session Discussion This requirement ensures accessibility to the voter throughout the entire session Not only must individual system components such as ballot markers paper records and optical scanners be accessible but also they must work together to support this result i The manufacturer shall supply documentation describing 1 recommended procedures that fully implement accessibility for voters with disabilities and 2 how the Acc-VS supports those procedures Discussion The purpose of this requirement is for the manufacturer not simply to deliver system components but also to describe the accessibility scenarios they are intended to support b When the provision of accessibility for the Acc-VS involves an alternative format for ballot presentation then all information presented to non-disabled voters including instructions warnings error and other messages and contest choices shall be presented in that alternative format c The support provided to voters with disabilities shall be intrinsic to the Acc-VS Personal assistive devices of the voter shall not be necessary to operate the Acc-VS correctly This does not apply to personal assistive technology required to comply with 3 3 4 b Discussion This requirement does not preclude the Acc-VS from providing interfaces to assistive technology See definition of personal assistive devices in Appendix A Its purpose is to assure that disabled voters are not required to bring special devices with them in order to vote successfully The requirement does not assert that the Acc-VS will eliminate the need for a voter's ordinary non-interfacing devices such as eyeglasses or canes 6 For additional clarification see EAC Decision on Request for Interpretation 2010-06 http www eac gov assets 1 AssetManager RFI 201006 Applying_Accessbility_requirements_to_BMD FINAL pdf 64 d If a voting system provides for voter identification or authentication by using biometric measures that require a voter to possess particular biological characteristics then the Acc-VS shall provide a secondary means that does not depend on those characteristics Discussion For example if fingerprints are used for voter identification another mechanism must be provided for voters without usable fingerprints e If the Acc-VS generates a paper record or some other durable human-readable record that can be the official ballot or determinative vote record then the voting system shall allow the voter to verify that record using the same access features used by the voter to cast the ballot Discussion While paper records generally provide a simple and effective means for technology-independent vote verification their use can present difficulties for voters with certain types of disabilities The purpose of this requirement is to ensure that all voters have a similar opportunity for vote verification 7 Note that this requirement addresses the special difficulties that may arise with the use of paper Verification is part of the voting process and all the other general requirements apply to verification in particular those dealing with dexterity e g 3 3 4 c blindness e g 3 3 3 e and low vision issues e g 3 2 5 g This requirement allows the voter to use the same access features throughout the entire voting session It also does not preclude the voter from choosing a different access feature to verify the record See also requirement 3 2 2 1 g 3 3 2 Enhanced visual interfaces These requirements specify the features of the Acc-VS designed to make the visual interface easier to see in particular for voters with vision deficiencies and synchronized with audio for voters with various language reading or some cognitive disabilities In general low vision is defined as having a visual acuity worse than 20 70 Low or partial vision also includes dimness of vision haziness film over the eye foggy vision extreme near-sightedness or far-sightedness distortion of vision color distortion or blindness visual field defects spots before the eyes tunnel vision lack of peripheral vision abnormal sensitivity to light or glare and night blindness People with tunnel vision can see only a small part of the ballot at one time For these users it is helpful to have letters at the lower end of the font size range in order to allow them to see more letters at the same time Thus there is a need to provide font sizes at both ends of the range 7 For additional clarification see EAC Decision on Request for Interpretation 2009-01 http www eac gov assets 1 Page EAC Decision on VVPAT Accessibility pdf 65 People with low vision or color blindness benefit from high contrast and from a selection of color combinations appropriate for their needs Between 7% and 10% of all men have color vision deficiencies Certain color combinations in particular cause problems Therefore use of color combinations with good contrast is required Note also the general Requirement 3 2 5 h i However some users are very sensitive to very bright displays and cannot use them for long An overly bright background causes a visual white-out that makes these users unable to distinguish individual letters Thus use of non-saturated color options is an advantage for some people It is important to note that some of the requirements in 3 2 5 Visual display characteristics also provide support for voters with certain kinds of vision problems a An Acc-VS with a color electronic image display shall allow the voter to adjust the color saturation throughout the voting session while preserving the current votes i At a minimum two alternative display options listed shall be available 1 black text on white background 2 white text on black background 3 yellow text on a black background or 4 light cyan text on a black background b Groups of buttons and controls which perform different functions on the Acc-VS shall be distinguishable by both shape and color This applies to buttons and controls implemented either on-screen or in hardware This requirement does not apply to sizeable groups of keys in wide use by individuals with disabilities such as a full alphabetic keyboard when used for purposes other than basic navigation and selection e g entering a write-in candidate name Discussion The redundant cues assist those with low vision They also help individuals who may have difficulty reading the text on the screen those who are blind but have some residual vision and those who use the controls on an Acc-VS because of limited dexterity While this requirement is primarily focused on those with low vision a feature intended primarily to address one kind of disability may very well assist voters with other kinds 8 The TRACE Center's EZ Access design is an example of button functions distinguishable by both shape and color http trace wisc edu ez c If the Acc-VS has an electronic image display the Acc-VS shall provide synchronized audio output to convey the same information as that which is displayed on the screen i There shall be a means by which the voter can disable either the audio or the video output resulting in a video-only or audio-only presentation respectively ii The system shall allow the voter to switch among the three modes synchronized audio video video-only or audio-only throughout the voting session while preserving the current votes 8 For additional information see EAC Decision on Request for Interpretation 2007-01 http www eac gov assets 1 Page EAC%20Decision%20on%20Accessible%20Design pdf 66 Discussion This feature may also assist voters with cognitive disabilities 3 3 3 Audio-tactile interfaces These requirements specify the features of the Acc-VS designed to not only assist voters who are blind but also those voters who would benefit from an auditory rather than a purely visual interface a The manufacturer shall conduct summative usability tests on the Acc-VS using individuals who are blind and shall report the test results using the Common Industry Format as part of the TDP i In addition the usability test report shall be submitted to the EAC as part of the documentation manufacturers are required to file with the application to test a voting system b The Acc-VS shall provide an audio-tactile interface ATI that supports the full functionality of the visual ballot interface Discussion Note the necessity of both audio output and tactilely discernible controls for voter input Full functionality includes at least o o o o o o Instructions and feedback on initial activation of the ballot such as insertion of a smart card if applicable Instructions and feedback to the voter on how to operate the accessible voting station including settings and options e g volume control repetition Instructions and feedback for navigation of the ballot Instructions and feedback for contest choices including write-in candidates Instructions and feedback on confirming and changing votes and Instructions and feedback on final submission of ballot i The ATI shall provide the same capabilities to vote and cast a ballot as are provided by its visual interface Discussion For example if a visual ballot supports voting a straight party ticket and then changing the vote for a single contest so must the ATI ii The ATI shall allow the voter to have any information provided by the voting system repeated Discussion This feature may also be useful to voters with cognitive disabilities iii The ATI shall allow the voter to pause and resume the audio presentation 67 Discussion This feature may also be useful to voters with cognitive disabilities iv The ATI shall allow the voter to skip to the next contest or return to previous contests Discussion This is analogous to the ability of sighted voters to move on to the next contest once they have made a selection or to abstain from voting on a contest altogether v The ATI shall allow the voter to skip over the reading of a referendum so as to be able to vote on it immediately Discussion This is analogous to the ability of sighted voters to skip over the wording of a referendum on which they have already made a decision prior to the voting session e g Vote yes on proposition #123 c Voting systems that provide audio presentation of the ballot shall do so in a usable way as detailed in the following sub-requirements Discussion These requirements apply to all voting system audio output not just to the ATI of an Acc-VS i The ATI shall provide its audio signal through an industry standard connector for private listening using a 3 5mm stereo headphone jack to allow voters to use their own audio assistive devices ii If the ATI utilizes a telephone style handset or headphone to provide audio information it shall provide a wireless T-Coil 9 coupling for assistive hearing devices so as to provide access to that information for voters with partial hearing That coupling shall achieve at least a category T4 rating as defined by ANSI01 American National Standard for Methods of Measurement of Compatibility between Wireless Communications Devices and Hearing Aids ANSI C63 19 Discussion Note that Requirement 3 3 6 c protects the use of hearing devices iii A sanitized headphone or handset shall be made available to each voter Discussion This requirement can be achieved in various ways including the use of throwaway headphones or of sanitary coverings iv The audio system shall set the initial volume for each voting session between 60 and 70 dB SPL 9 For additional clarification see EAC Decision on Request for Interpretation 2009-05 http www eac gov assets 1 Page EAC Decision on T-Coil Requirements pdf 68 Discussion A voter does not inherit the volume as set by the previous user of the voting station See requirement 3 2 5 b v The audio system shall allow the voter to control the volume throughout the voting session while preserving the current votes The volume shall be adjustable from a minimum of 20dB SPL up to a maximum of 100 dB SPL in increments no greater than 10 dB vi The audio system shall be able to reproduce frequencies over the audible speech range of 315 Hz to 10 KHz Discussion The required frequencies include the range of normal human speech This allows the reproduced speech to sound natural vii The audio presentation of verbal information should be readily comprehensible by voters who have normal hearing and are proficient in the language This includes such characteristics as proper enunciation normal intonation appropriate rate of speech and low background noise Candidate names should be pronounced as the candidate intends Discussion This requirement covers both recorded and synthetic speech It applies to those aspects of the audio content that are inherent to the voting system or that are generated by default To the extent that the audio presentation is determined by election officials designing the ballot it is beyond of the scope of this requirement viii The audio system shall allow the voter to control the rate of speech throughout the voting session while preserving the current votes The range of speeds supported shall include 75% to 200% of the nominal rate Adjusting the rate of speech shall not affect the pitch of the voice Discussion Many blind voters are accustomed to interacting with accelerated speech This feature may also be useful to voters with cognitive disabilities d If the Acc-VS supports ballot activation for non-blind voters then it shall also provide features that enable voters who are blind to perform this activation Discussion For example smart cards might provide tactile cues so as to allow correct insertion e If the Acc-VS supports ballot submission or vote verification for non-blind voters then it shall also provide features that enable voters who are blind to perform these actions 69 Discussion For example if voters using this station normally perform paperbased verification or if they feed their own optical scan ballots into a reader blind voters must also be able to do so f Mechanically operated controls or keys or any other hardware interface on the AccVS available to the voter shall be tactilely discernible without activating those controls or keys Discussion A blind voter should be able to operate the Acc-VS by feel alone This means that vision should not be necessary for such operations as inserting a smart card or plugging into a headphone jack Note also the more general Requirement 3 2 6 c against accidental activation of controls g The status of all locking or toggle controls or keys such as the shift key for the Acc-VS shall be visually discernible and also discernible through either touch or sound 3 3 4 Enhanced input and control characteristics These requirements specify the features of the Acc-VS designed to assist voters who lack fine motor control or use of their hands a The Acc-VS shall provide a 3 5 mm industry standard jack used to connect a personal assistive technology switch to the Acc-VS This jack shall allow only switch data to be transmitted to the voting system The voting system shall accept switch input that is functionally equivalent to tactile input All the functionality of the Acc-VS e g straight party voting write-in candidates that is available through the conventional forms of input such as tactile shall also be available through this non-manual input mechanism Discussion This requirement ensures that the Acc-VS are operable by individuals who do not have the use of their hands Examples of non-manual controls include sip and puff switches While it is desirable that the voter be able to independently initiate use of the non-manual input mechanism this requirement guarantees only that the voter can vote independently once the mechanism is enabled b The Acc-VS shall provide features that enable voters who lack fine motor control or the use of their hands to submit their ballots privately and independently without manually handling the ballot 70 Discussion For example if voters using this station normally perform paperbased verification or if they feed their own optical scan ballots into a reader voters with dexterity disabilities must also be able to do so Note that the general requirement for privacy when voting Requirement part 1 3 2 3 1 a still applies c Keys controls and other manual operations on the Acc-VS shall be operable with one hand and shall not require tight grasping pinching or twisting of the wrist The force required to activate controls and keys shall be no greater 5 lbs 22 2 N Discussion Controls are to be operable without excessive force This includes operations such as inserting an activation card and inserting and removing ballots d The Acc-VS controls shall not require direct bodily contact or for the body to be part of any electrical circuit Discussion This requirement ensures that controls are operable by individuals using prosthetic devices 3 3 5 Design for mobility aids These requirements specify the features of the Acc-VS designed to assist voters who use mobility aids including wheelchairs Many of the requirements of this section are based on the ADA Accessibility Guidelines for Buildings and Facilities ADAAG a The Acc-VS shall provide a clear floor space of 30 inches minimum by 48 inches minimum for a stationary mobility aid The clear floor space shall be designed for a forward approach or a parallel approach b When deployed according to the installation instructions provided by the manufacturer the Acc-VS shall allow adequate room for an assistant to the voter This includes clearance for entry to and exit from the area of the voting station Discussion Disabled voters sometimes prefer to have an assistant help them vote The setup of the Acc-VS should not preclude this c Labels displays controls keys audio jacks and any other part of the Acc-VS necessary for the voter to operate the voting system shall be legible and visible to a voter in a wheelchair with normal eyesight no worse than 20 40 corrected who is in an appropriate position and orientation with respect to the Acc-VS 71 Discussion There are a number of factors that could make relevant parts of the Acc-VS difficult to see such as small lettering controls and labels tilted at an awkward angle from the voter's viewpoint and glare from overhead lighting 3 3 5 1 Controls within reach The requirements of this section ensure that the controls keys audio jacks and any other part of the Acc-VS necessary for its operation are within easy reach Note that these requirements have meaningful application mainly to controls in a fixed location A hand-held tethered control panel is another acceptable way of providing reachable controls a If the Acc-VS has a forward approach with no forward reach obstruction then the high reach shall be 48 inches maximum and the low reach shall be 15 inches minimum See Figure 1 b If the Acc-VS has a forward approach with a forward reach obstruction the following sub-requirements shall apply See Figure 2 i The forward obstruction for the Acc-VS shall be no greater than 25 inches in depth its top no higher than 34 inches and its bottom surface no lower than 27 inches ii If the obstruction for the Acc-VS is no more than 20 inches in depth then the maximum high reach shall be 48 inches otherwise it shall be 44 inches iii Space under the obstruction between the finish floor or ground and 9 inches above the finish floor or ground shall be considered toe clearance and shall comply with the following provisions for the Acc-VS o Toe clearance depth shall extend 25 inches maximum under the obstruction o The minimum toe clearance depth under the obstruction shall be either 17 inches or the depth required to reach over the obstruction to operate the AccVS whichever is greater and o Toe clearance width shall be 30 inches minimum iv Space under the obstruction between 9 inches and 27 inches above the finish floor or ground shall be considered knee clearance and shall comply with the following provisions o Knee clearance depth shall extend 25 inches maximum under the obstruction at 9 inches above the finish floor or ground o The minimum knee clearance depth at 9 inches above the finish floor or ground shall be either 11 inches or 6 inches less than the toe clearance whichever is greater o Between 9 inches and 27 inches above the finish floor or ground the knee clearance depth shall be permitted to reduce at a rate of 1 inch in depth for each 6 inches in height It follows that the minimum knee clearance at 27 inches above the finish floor or ground shall be 3 inches less than the minimum knee clearance at 9 inches above the floor and o Knee clearance width shall be 30 inches minimum 72 c If the Acc-VS has a parallel approach with no side reach obstruction then the maximum high reach shall be 48 inches and the minimum low reach shall be 15 inches See Figure 3 d If the Acc-VS has a parallel approach with a side reach obstruction the following sub-requirements shall apply See Figure 4 Discussion Since this is a parallel approach no clearance under the obstruction is required i The side obstruction for the Acc-VS shall be no greater than 24 inches in depth and its top no higher than 34 inches ii If the obstruction is no more than 10 inches in depth then the maximum high reach shall be 48 inches otherwise it shall be 46 inches Figures 1-4 Unobstructed reach measurements Dimensions shown in inches above the line SI units in millimeters below the line Figure 1 Unobstructed forward reach Figure 2 Obstructed forward reach a for an obstruction depth of up to 20 inches b for an obstruction depth of up to 25 inches Figure 3 Unobstructed side reach with an allowable obstruction less than 10 inches deep Figure 4 Obstructed side reach a for an obstruction depth of up to 10 inches 73 b for an obstruction depth of up to 24 inches 3 3 6 Enhanced auditory interfaces These requirements specify the features of the Acc-VS designed to assist voters with hearing disabilities a The Acc-VS shall incorporate the features listed under Requirement 3 3 3 c for voting systems that provide audio presentation of the ballot Discussion Note especially the requirements for volume initialization and control b If the Acc-VS provides sound cues as a method to alert the voter the tone shall be accompanied by a visual cue unless the station is in audio-only mode Discussion For instance the voting equipment might beep if the voter attempts to overvote If so there would have to be an equivalent visual cue such as the appearance of an icon or a blinking element If the Acc-VS has been set to audio-only mode there would be no visual cue c No voting device shall cause electromagnetic interference with assistive hearing devices that would substantially degrade the performance of those devices The voting device measured as if it were a wireless device shall achieve at least a category T4 rating as defined by ANSI01 American National Standard for Methods of Measurement of Compatibility between Wireless Communications Devices and Hearing Aids ANSI C63 19 Discussion Hearing devices include hearing aids and cochlear implants 3 3 7 Design in support of cognitive disabilities These requirements specify the features of the Acc-VS designed to assist voters with cognitive disabilities a The Acc-VS should provide support to voters with cognitive disabilities Discussion Because of the highly varied nature of disabilities falling within the cognitive category there are no design features uniquely aimed at helping those with such disabilities However many of the features designed primarily for other disabilities and for general usability are also highly relevant to these voters 74 o o o o The synchronization of audio with the displayed screen information Requirement 3 3 2 d Requirement 3 2 4 and in particular the use of plain language Requirement 3 2 4 c Large font sizes and legibility of paper Requirement 3 2 5 e and 3 2 5 g and The ability to control various aspects of the audio presentation Requirement 3 3 3 b and 3 3 3 c such as pausing repetition and speed 3 3 8 English proficiency This requirement specifies the features of the Acc-VS designed to assist voters who lack proficiency in reading English a For voters who lack proficiency in reading English the Acc-VS shall provide an audio interface for instructions and ballots as described in 3 3 3 b 3 3 9 Speech not required a The voting system shall not require voter speech for its operation Discussion This does not preclude voting systems from offering speech input as an option but speech must not be the only means of input 3 3 10 Summative Usability Report a The manufacturer shall submit a report of their summative usability tests on the voting system using individuals who are representative of the general population i The report shall be submitted in the Common Industry Format ii The report shall contain the results of the summative usability tests b The manufacturer shall conduct summative usability tests on the Acc-VS using individuals with low vision and shall report the test results using the Common Industry Format as part of the TDP i In addition the usability test report shall be submitted to the EAC as part of the documentation manufacturers are required to file with the application to test a voting system c The manufacturer shall conduct summative usability tests on the Acc-VS using individuals lacking fine motor control and shall report the test results using the Common Industry Format as part of the TDP i In addition the usability test report shall be submitted to the EAC as part of the documentation manufacturers are required to file with the application to test a voting system 75 Discussion Voting system developers are required to conduct realistic usability tests on their product before submitting the system to conformance testing This is to encourage early detection and resolution of usability problems The manufacturer must submit the usability test report to the VSTL as part of their TDP The VSTL will then check the technical data package to ensure that the report is present and reported in the Common Industry Format and contains the results from a summative usability test 10 10 The italicized text in Section 3 2 1 is based on EAC Decision on a Request for Interpretation 2007-03 http www eac gov assets 1 Page EAC%20Decision%20on%20Summative%20Usability%20Testing pdf 76 4 Hardware Requirements Table of Contents 4 4 1 4 1 1 4 1 2 4 1 3 4 1 4 4 1 5 4 1 6 4 1 7 4 1 8 4 2 4 2 1 4 2 2 4 2 3 4 3 4 3 1 4 3 2 4 3 3 4 3 4 4 3 5 4 3 6 Hardware Requirements Performance Requirements Accuracy Requirements Environmental Requirements Election Management System Requirements Vote Recording Requirements Paper-based Conversion Requirements Tabulation Processing Requirements Reporting Requirements Vote Data Management Requirements Physical Characteristics Size Weight Transport and Storage of Precinct Systems Design Construction and Maintenance Characteristics Materials Processes and Parts Durability Reliability Product Marking Workmanship Safety 77 78 79 79 81 86 86 89 91 92 93 94 94 94 94 94 94 95 95 98 98 98 Voting System Performance Guidelines 4 Hardware Requirements 4 Hardware Requirements This section contains the requirements for the machines and manufactured devices that are part of a voting system It specifies minimum values for certain performance characteristics physical characteristics and design construction and maintenance characteristics for the hardware and selected related components of all voting systems such as o o o o o o o o o o o o o Ballot printers Ballots Ballot displays Voting devices including ballot marking devices and DRE recording devices Voting booths and enclosures Ballot boxes and ballot transfer boxes Ballot readers Computers used to prepare ballots program elections consolidate and report votes and perform other elections management activities Electronic ballot recorders Electronic precinct vote control units Removable electronic data storage media Servers Printers This section applies to the combination of software and hardware to accomplish specific performance and system control requirements Standards that are specific to software alone are provided in Section 5 The requirements of this section apply generally to all hardware used in voting systems including o Hardware provided by the voting system manufacturer and its suppliers o Hardware furnished by an external provider for example providers of commercial-off-the-shelf equipment where the hardware may be used in any way during voting system operation o Hardware provided by the voting jurisdiction The requirements presented in this section are organized as follows Performance Requirements These requirements address the combined operational capabilities of the voting system hardware and software across a broad range of parameters Physical Requirements These requirements address the size weight and transportability of the voting system Design Construction and Maintenance Requirements These requirements address the reliability and durability of materials product marking quality of system 78 Voting System Performance Guidelines 4 Hardware Requirements workmanship safety and other attributes to ensure smooth system operation in the voting environment 4 1 Performance Requirements The performance requirements address a broad range of parameters encompassing o Accuracy requirements where requirements are specified for distinct processing functions of paper-based and DRE systems o Environmental requirements where no distinction is made between requirements for paper-based and DRE systems but requirements for precinct and central count are described o Vote data management requirements where no differentiation is made between requirements for paper-based and DRE systems o Vote recording requirements where separate and distinct requirements are delineated for paper-based and DRE systems o Conversion requirements which apply only to paper-based systems o Processing requirements where separate and distinct requirements are delineated for paper-based and DRE systems o Reporting requirements where no distinction is made between requirements for paper-based and DRE systems but where differences between precinct and central count systems are readily apparent based on differences of their reporting The performance requirements include such attributes as ballot reading and handling requirements system accuracy memory stability and the ability to withstand specified environmental conditions These characteristics also encompass system-wide requirements for shelter electrical supply and compatibility with data networks Performance requirements for voting systems represent the combined operational capability of both system hardware and software Accuracy as measured by data error rate and operational failure are treated as distinct attributes in performance testing All systems shall meet the performance requirements under operating conditions and after storage under non-operating conditions 4 1 1 Accuracy Requirements The following requirements are intended to allow tolerance for unpreventable hardwarerelated errors that occur rarely and randomly as a result of physical phenomena They are not intended to allow tolerance of software faults that result in systematic miscounting of votes Section 2 1 2 includes a requirement for accuracy of logic a All systems shall achieve a report total error rate of no more than one in 125 000 8x10-6 b Given a set of vote data reports the observed cumulative report total error rate shall be calculated as follows 79 Voting System Performance Guidelines 4 Hardware Requirements i Define a report item as any one of the numeric values totals or counts that must appear in any of the vote data reports Each ballot count each vote overvote and undervote total for each contest and each vote total for each contest choice in each contest is a separate report item The required report items are detailed in Volume I Section 2 4 3 ii For each report item compute the report item error as the absolute value of the difference between the correct value and the reported value Special cases If a value is reported that should not have appeared at all spurious item or if an item that should have appeared in the report does not missing item assess a report item error of one Additional values that are reported as a manufacturer extension to the standard are not considered spurious items iii Compute the report total error as the sum of all of the report item errors from all of the reports iv Compute the report total volume as the sum of all of the correct values for all of the report items that are supposed to appear in the reports Special cases When the same logical contest appears multiple times e g when results are reported for each ballot configuration and then combined or when reports are generated for multiple reporting contexts each manifestation of the logical contest is considered a separate contest with its own correct vote totals in this computation v Compute the observed cumulative report total error rate as the ratio of the report total error to the report total volume Special cases If both values are zero the report total error rate is zero If the report total volume is zero but the report total error is not the report total error rate is infinite The benchmark of one in 125 000 8x10-6 is derived from the maximum acceptable error rate used as the lower test benchmark in the 2005 Voluntary Voting System Guidelines Version 1 0 That benchmark was defined as a ballot position error rate of one in 500 000 2x10-6 The benchmark of one in 125 000 is expressed in terms of votes 11 however it is consistent with the previous benchmark in that the estimated ratio of votes to ballot positions is 1 4 Given that there is no typical ratio of votes to ballot positions with such diversity among the many jurisdictions it is nevertheless necessary to base the benchmark on some rough estimates in order that it may be in the correct order of magnitude albeit not optimal for every case The estimated ratio was derived as follows In a presidential election there would be approximately 20 contests with a vote for 1 on each ballot with an average of 4 candidates including the write-in position per contest Some states would have fewer contests and some more A few contests like President would have 8- 13 candidates most would have 3 candidates including the write-in and a few would have 2 candidates Thus the estimated ratio of votes to ballot positions is 1 4 11 The error rate was originally defined in Volume 1 of the 2002 Voting System Standards and is prescribed by Sec 301 a 5 of the Help America Vote Act of 2002 Expressing this benchmark in terms of votes instead of ballot positions provides a more precise metric for the evaluation of accuracy 80 Voting System Performance Guidelines 4 Hardware Requirements 4 1 2 Environmental Requirements The environmental requirements for voting systems include shelter space furnishings and fixtures supplied energy environmental control and external telecommunications services Environmental conditions applicable to the design and operation of voting systems consist of the following categories o Natural environment including temperature humidity and atmospheric pressure o Induced environment including proper and improper operation and handling of the system and its components during the election processes o Transportation and storage o Electromagnetic signal environment including exposure to and generation of radio frequency energy a All voting systems shall be designed to withstand the environmental conditions contained in the appropriate test procedures of the Guidelines These procedures will be applied to all devices for casting scanning and counting ballots except those that constitute COTS devices that have not been modified in any manner to support their use as part of a voting system and that have a documented record of performance under conditions defined in the Guidelines b The Technical Data Package supplied by the manufacturer shall include a statement of all requirements and restrictions regarding i Environmental protection ii Electrical service iii Recommended auxiliary power iv Telecommunications service v Any other facility or resource required for the proper installation and operation of the system 4 1 2 1 Shelter Requirements All precinct count systems shall be designed for storage and operation in any enclosed facility ordinarily used as a warehouse or polling place with prominent instructions as to any special storage requirements 4 1 2 2 Space Requirements There is no restriction on space allowed for the installation of voting systems except that the arrangement of these systems shall not impede performance of their duties by polling place officials the orderly flow of voters through the polling place or the ability for the voter to vote in private 81 Voting System Performance Guidelines 4 Hardware Requirements 4 1 2 3 Furnishings and Fixtures Any furnishings or fixtures provided as a part of voting systems and any components provided by the manufacturer that are not a part of the voting system but that are used to support its storage transportation or operation shall comply with the safety design of Subsection 4 3 6 4 1 2 4 Electrical Supply Components of voting systems that require an electrical supply shall meet the following standards a Precinct count voting systems shall operate with the electrical supply ordinarily found in polling places Nominal 120 Vac 60Hz 1 phase b Central count voting systems shall operate with the electrical supply ordinarily found in central tabulation facilities or computer room facilities Nominal 120 Vac 60Hz 1 nominal 208 Vac 60Hz 3 or nominal 240 Vac 60Hz 2 c Precinct count voting machines shall also be capable of operating for a period of at least 2 hours on backup power such that no voting data is lost or corrupted nor normal operations interrupted When backup power is exhausted the voting machine shall retain the contents of all memories intact Discussion All forms of voting equipment including optical scan shall include battery backup 12 The backup power capability is not required to provide lighting of the voting area Central count systems are not required to have a 2 hour battery backup d A central count system shall provide for a graceful shutdown to allow switching to an alternate power source The shutdown can be implemented either by means of a user controlled intervention or an automatic systematic operation e The graceful shutdown shall meet the following requirements i The alert to the user that the system has lost power and is shutting down systematic or needs to be shut down user intervention should be easily recognizable and documentation should be provided to illustrate the proper course of action that needs to be taken ii All ballots shall reside in either the input or output hopper with no ballots in process at the end of the shutdown process iii All ballots in the output hopper shall be fully read and saved iv All actions taken by the system or the user to initiate the shut down are considered events and shall be logged per Requirements 2 1 5 1 12 The italicized text in the discussion box is based specifically on EAC Decision on Request for Interpretation 2008-02 http www eac gov assets 1 Page EAC%20Decision%20on%20Battery%20Backup%20for%20Optical%2 0Scan%20Voting%20Machines pdf 82 Voting System Performance Guidelines 4 Hardware Requirements v A report including the final state of all ballots timestamps and of the final state of the unit shall be printed or saved in a file The report shall be part of the permanent election record and shall be available when power is restored to the system vi The system shall be capable of resuming operation from the point it stopped once power is restored f Testing for the graceful shutdown shall maintain ballots in the input hopper through the shutdown process The purpose of this requirement is to confirm that the system will stop processing further ballots complete ballots in process and save a report that accurately identifies the final state of the ballots and the system g The second part of the test shall restore power to the system and confirm that the system restarts properly and that the status report reflects accurately the state of the ballots and the system 13 4 1 2 5 Electrical Power Disturbance Vote scanning and counting equipment for paper-based voting systems and all DRE voting equipment shall be able to withstand without disruption of normal operation or loss of data a b c d e Voltage dip of 30% of nominal @10 ms Voltage dip of 60% of nominal @100 ms 1 sec Voltage dip of 95% interrupt @5 sec Surges of 15% line variations of nominal line voltage Electric power increases of 7 5% and reductions of 12 5% of nominal specified power supply for a period of up to four hours at each power level 4 1 2 6 Electrical Fast Transient Vote scanning and counting equipment for paper-based systems and all DRE equipment shall be able to withstand without disruption of normal operation or loss of data electrical fast transients of a 2 kV and -2 kV on External Power lines both AC and DC b 1 kV and -1 kV on Input Output lines signal data and control lines longer than 3 meters c Repetition Rate for all transient pulses will be 100 kHz 13 The italicized text in 4 1 2 4 d-i is based on EAC Decision on Request for Interpretation 2008-06 http www eac gov assets 1 Page EAC%20Decision%20on%20Battery%20Backup%20for%20Central%2 0Count pdf and 2009-03 http www eac gov assets 1 Page EAC%20Decision%20on%20Battery%20Back%20Up%20for%20Centr al%20Count%20Systems pdf 83 Voting System Performance Guidelines 4 Hardware Requirements 4 1 2 7 Lightning Surge Vote scanning and counting equipment for paper-based systems and all DRE equipment shall be able to withstand without disruption of normal operation or loss of data surges of a b c d e 2 kV AC line to line 2 kV AC line to earth or - 0 5 kV DC line to line 10m or - 0 5 kV DC line to earth 10m 1 kV I O sig control 30m 4 1 2 8 Electrostatic Disruption Vote scanning and counting equipment for paper-based systems and all DRE equipment shall be able to withstand 15 kV air discharge and 8 kV contact discharge without damage or loss of data The equipment may reset or have momentary interruption so long as normal operation is resumed without human intervention or loss of data Loss of data means votes that have been completed and confirmed to the voter 4 1 2 9 Electromagnetic Emissions All voting equipment shall comply with the Rules and Regulations of the Federal Communications Commission Part 15 Class B requirements for both radiated and conducted emissions 4 1 2 10 Electromagnetic Susceptibility Vote scanning and counting equipment for paper-based systems and all DRE equipment shall be able to withstand an electromagnetic field of 10 V m modulated by a 1 kHz 80% AM modulation over the frequency range of 80 MHz to 1000 MHz without disruption of normal operation or loss of data 4 1 2 11 Conducted RF Immunity Vote scanning and counting equipment for paper-based systems and all DRE equipment shall be able to withstand without disruption of normal operation or loss of data conducted RF energy of a 10V rms over the frequency range 150 KHz to 80 MHz with an 80% amplitude modulation with a 1 KHz sine wave AC DC power 84 Voting System Performance Guidelines 4 Hardware Requirements b 10V sig control 3 m over the frequency range 150 KHz to 80 MHz with an 80% amplitude modulation with a 1 KHz sine wave 4 1 2 12 Magnetic Fields Immunity Vote scanning and counting equipment for paper-based systems and all DRE equipment shall be able to withstand without disruption of normal operation or loss of data AC magnetic fields of 30 A m at 60 Hz 4 1 2 13 Environmental Control - Operating Environment a Voting systems shall be capable of operation in temperatures ranging from 41 F to 104 F 5 C to 40 C and relative humidity from 5% to 85% noncondensing b If the system documentation states that the system can operate in humidity higher or lower than the required range the system shall be tested to the level of humidity asserted in the documentation For testing information see Volume II section 5 7 1 4 1 2 14 Environmental Control - Transit and Storage Equipment used for vote casting or for counting votes in a precinct count system shall meet these specific minimum performance standards that simulate exposure to physical shock and vibration associated with handling and transportation by surface and air common carriers and to temperature conditions associated with delivery and storage in an uncontrolled warehouse environment a High and low storage temperatures ranging from -4 to 140 degrees Fahrenheit equivalent to MIL-STD-810D Methods 501 2 and 502 2 Procedure I-Storage b Bench handling equivalent to the procedure of MIL-STD-810D Method 516 3 Procedure VI c Vibration equivalent to the procedure of MIL-STD-810D Method 514 3 Category 1- Basic Transportation Common Carrier d Uncontrolled humidity equivalent to the procedure of MIL-STD-810D Method 507 2 Procedure I-Natural Hot-Humid 4 1 2 15 Data Network Requirements Voting systems may use a local or remote data network If such a network is used then all components of the network shall comply with the telecommunications requirements described in Section 6 and the Security requirements described in Section 7 85 Voting System Performance Guidelines 4 Hardware Requirements 4 1 3 Election Management System Requirements The Election Management System EMS requirements address electronic hardware and software used to conduct the pre-voting functions defined in Section 2 with regard to ballot preparation election programming ballot and program installation readiness testing verification at the polling place and verification at the central location 4 1 3 1 Recording Requirements Voting systems shall accurately record all election management data entered by the user including election officials or their designees For recording accuracy all systems shall a Record every entry made by the user b Add permissible voter selections correctly to the memory components of the device c Verify the correctness of detection of the user selections and the addition of the selections correctly to memory d Add various forms of data entered directly by the election official or designee such as text line art logos and images e Verify the correctness of detection of data entered directly by the user and the addition of the selections correctly to memory f Preserve the integrity of election management data stored in memory against corruption by stray electromagnetic emissions and internally generated spurious electrical signals g Log corrected data errors by the voting system 4 1 3 2 Memory Stability Memory devices used to retain election management data shall have demonstrated errorfree data retention for a period of 22 months 4 1 4 Vote Recording Requirements The vote recording requirements address the enclosure equipment and supplies used by voters to vote 86 Voting System Performance Guidelines 4 Hardware Requirements 4 1 4 1 Common Requirements All voting systems shall provide voting booths or enclosures for poll site use Such booths or enclosures may be integral to the voting system or supplied as components of the voting system and shall a Be integral to or make provision for the installation of the voting machine b Ensure by its structure stability against movement or overturning during entry occupancy and exit by the voter c Provide privacy for the voter and be designed in such a way as to prevent observation of the ballot by any person other than the voter d Be capable of meeting the accessibility requirements of Subsection 3 2 4 1 4 2 Paper-based Recording Requirements The paper-based recording requirements govern o Ballots sheets and pages or assemblies of pages containing ballot field identification data o Ballot marking devices o Frames or fixtures to hold the ballot while it is being marked o Compartments or booths where voters record selections o Secure containers for the collection of voted ballots a Paper ballots used by paper-based voting systems shall meet the following standards i Marks that identify the unique ballot format shall be outside the area in which votes are recorded so as to minimize the likelihood that these marks will be mistaken for vote responses and the likelihood that recorded votes will obliterate these marks ii If printed alignment marks are used to locate the vote response fields on the ballot these marks shall be outside the area in which votes are recorded so as to minimize the likelihood that these marks will be mistaken for vote responses and the likelihood that recorded votes will obliterate these marks iii The Technical Data Package shall specify the required paper stock size shape opacity color watermarks field layout orientation size and style of printing size and location of mark fields used for vote response fields and to identify unique ballot formats placement of alignment marks ink for printing and folding and bleed-through limitations for preparation of ballots that are compatible with the system b The Technical Data Package shall specify marking devices which if used to make the prescribed form of mark produce readable marked ballots such that the system meets the performance requirements for accuracy in Subsection 4 1 1 Marking devices can be either manual such as pens or pencils or electronic These specifications shall identify i Specific characteristics of marking devices that affect readability of marked ballots 87 Voting System Performance Guidelines 4 Hardware Requirements ii Performance capabilities with regard to each characteristic iii For marking devices manufactured by multiple external sources a listing of sources and model numbers that are compatible with the system c A frame or fixture for printed ballots is optional However if such a device is provided it shall i Be of any size and shape consistent with its intended use ii Position the card properly iii Hold the ballot securely in its proper location and orientation for voting iv Comply with the requirements for design and construction contained in Subsection 4 3 d Ballot boxes and ballot transfer boxes which serve as secure containers for the storage and transportation of voted ballots shall i Be of any size shape and weight commensurate with their intended use ii Incorporate locks or seals the specifications of which are described in the system documentation iii Provide specific points where ballots are inserted with all other points on the box constructed in a manner that prevents ballot insertion iv For precinct count systems contain separate compartments for the segregation of unread ballots ballots containing write-in votes or any irregularities that may require special handling or processing In lieu of compartments the conversion processing may mark such ballots with an identifying spot or stripe to facilitate manual segregation 4 1 4 3 DRE System Recording Requirements The DRE system recording requirements address the detection and recording of votes including the logic and data processing functions required to determine the validity of voter selections to accept and record valid selections and to reject invalid selections The requirements also address the physical environment in which ballots are cast a DRE systems shall include an audible or visible activity indicator providing the status of each voting device This indicator shall i Indicate whether the device has been activated for voting ii Indicate whether the device is in use b To ensure vote recording accuracy and integrity while protecting the anonymity of the voter all DRE systems shall i Contain all mechanical electromechanical and electronic components software and controls required to detect and record the activation of selections made by the voter in the process of voting and casting a ballot ii Incorporate redundant memories to detect and allow correction of errors caused by the failure of any of the individual memories iii Provide at least two processes that record the voter's selections that To the extent possible are isolated from each other Designate one process and associated storage location as the main vote detection interpretation processing and reporting path 88 Voting System Performance Guidelines 4 Hardware Requirements iv Use a different process to store ballot images for which the method of recording may include any appropriate encoding or data compression procedure consistent with the regeneration of an unequivocal record of the ballot as cast by the voter v Provide a capability to retrieve ballot images in a form readable by humans vi Ensure that all processing and storage protects the anonymity of the voter c DRE systems shall meet the following requirements for recording accurately each vote and ballot cast i Detect every selection made by the voter ii Correctly add permissible selections to the memory components of the device iii Verify the correctness of the detection of the voter selections and the addition of the selections to memory iv Maintain absolute correctness introduce no errors in the recording tabulating and reporting of votes by software firmware and hardwired logic per Requirement 2 1 2 g v Achieve an error rate that enables satisfaction of the system-level hardware accuracy requirement indicated in Subsection 4 1 1 vi Preserve the integrity of voting data and ballot images for DRE machines stored in memory for the official vote count and audit trail purposes against corruption by stray electromagnetic emissions and internally generated spurious electrical signals vii Maintain a log of corrected data 4 1 5 Paper-based Conversion Requirements The paper-based conversion requirements address the ability of the system to read the ballot and to translate its pattern of marks into electronic signals for later processing These capabilities may be built into the voting system in an integrated fashion or may be provided by one or more components that are not unique to the system such as a general purpose data processing ballot reader or read head suitably interfaced to the system These requirements address two major functions ballot handling and ballot reading 4 1 5 1 Ballot Handling Ballot handling consists of a ballot's acceptance movement through the read station and transfer into a collection station or receptacle a The capacity to convert the marks on individual ballots into signals is uniquely important to central count systems The capacity for a central count system shall be documented by the manufacturer This documentation shall include the capacity for individual components that impact the overall capacity b When ballots are unreadable or some condition is detected requiring that the ballots be segregated from normally processed ballots for human review e g write-ins all central count paper-based systems shall do one of the following i Outstack the ballot 89 Voting System Performance Guidelines 4 Hardware Requirements ii Stop the ballot reader and display a message prompting the election official or designee to remove the ballot iii Mark the ballot with an identifying mark to facilitate its later identification c Additionally the system shall provide a capability that can be activated by an authorized election official to identify ballots containing overvotes blank ballots and ballots containing undervotes in a designated contest If enabled these capabilities shall perform one of the above actions in response to the indicated condition d When ballots are unreadable or when some condition is detected requiring that the ballots be segregated from normally processed ballots for human review e g write-in votes all precinct count systems shall i In response to an unreadable or blank ballot return the ballot and provide a message prompting the voter to examine the ballot ii In response to a ballot with a write-in vote segregate the ballot or mark the ballot with an identifying mark to facilitate its later identification iii In response to a ballot with an overvote the system shall Provide a capability to identify an overvoted ballot Return the ballot Provide an indication prompting the voter to examine the ballot Allow the voter to correct the ballot Provide a means for an authorized election official to deactivate this capability entirely and by contest iv In response to a ballot with an undervote the system shall Provide a capability to identify an undervoted ballot Return the ballot Provide an indication prompting the voter to examine the ballot Allow the voter to correct the ballot Allow the voter to submit the ballot with the undervote Provide a means for an authorized election official to deactivate this capability e Ballot readers shall prevent multiple feed or detect and provide an alarm indicating multiple feed Multiple feed occurs when a ballot reader attempts to read more than one ballot at a time i If multiple feed is detected the ballot reader shall halt in a manner that permits the operator to remove the unread ballots causing the error and reinsert them in the input hopper Multiple feeds misfeeds jams and rejections of ballots that meet all manufacturer specifications are all treated collectively as misfeeds for benchmarking purposes i e only a single count is maintained f All paper-based tabulators and EBMs shall achieve a misfeed rate of no more than 0 002 1 500 g The observed cumulative misfeed rate shall be calculated as follows i Compute the misfeed total as the number of times that unforced multiple feed misfeed jam or rejection of a ballot that meets all manufacturer specifications has occurred during the execution of tests It is possible for a given ballot to misfeed more than once each misfeed would be counted 90 Voting System Performance Guidelines 4 Hardware Requirements ii Compute the total ballot volume as the number of successful feeds of ballot pages during the execution of tests If the pages of a multi-page ballot are fed separately each page counts but if both sides of a two-sided ballot are read in one pass through the tabulator it only counts once iii Compute the observed cumulative misfeed rate as the ratio of the misfeed total to the total ballot volume Special cases If both values are zero the misfeed rate is zero If the total ballot volume is zero but the misfeed total is not the misfeed rate is infinite 4 1 5 2 Ballot Reading Accuracy This paper-based system requirement governs the conversion of the physical ballot into electronic data Reading accuracy for ballot conversion refers to the ability to a Recognize vote punches or marks or the absence thereof for each possible selection on the ballot b Discriminate between valid punches or marks and extraneous perforations smudges and folds c Convert the vote punches or marks or the absence thereof for each possible selection on the ballot into digital signals To ensure accuracy paper-based systems shall d Detect marks that conform to manufacturer specifications with an error rate that enables satisfaction of the system-level accuracy requirement indicated in Subsection 4 1 1 e Ignore and not record extraneous perforations smudges and folds 4 1 6 Tabulation Processing Requirements Tabulation processing requirements apply to the hardware and software required to accumulate voting data for all candidates and measures within voting machines and polling places and to consolidate the voting data at a central level or multiple levels These requirements also address the generation and maintenance of audit records the detection and disabling of improper use or operation of the system and the monitoring of overall system status Separate and distinct requirements for paper-based and DRE voting systems are presented below 4 1 6 1 Paper-based System Processing Requirements The paper-based processing requirements address all mechanical devices electromechanical devices electronic devices and software required to perform the logical and numerical functions of interpreting the electronic image of the voted ballot and assigning votes to the proper memory registers 91 Voting System Performance Guidelines 4 Hardware Requirements a The ability of the system to produce and receive electronic signals from the scanning of the ballot perform logical and numerical operations upon these data and reproduce the contents of memory when required shall be sufficiently free of error to enable satisfaction of the system-level accuracy requirement indicated in Subsection 4 1 1 b Paper-based system memory devices used to retain control programs and data shall have demonstrated error-free data retention for a period of 22 months under the environmental conditions for operation and non-operation i e storage 4 1 6 2 DRE System Processing Requirements The DRE voting systems processing requirements address all mechanical devices electromechanical devices electronic devices and software required to process voting data after the polls are closed a Processing accuracy is defined as the ability of the system to process voting data stored in DRE voting devices or in removable memory modules installed in such devices Processing includes all operations to consolidate voting data after the polls have been closed DRE voting systems shall i Produce reports that are completely consistent with no discrepancy among reports of voting device data produced at any level ii Produce consolidated reports containing absentee provisional or other voting data that are similarly error-free Any discrepancy regardless of source is resolvable to a procedural error to the failure of a non-memory device or to an external cause b DRE system memory devices used to retain control programs and data shall have demonstrated error-free data retention for a period of 22 months Error-free retention may be achieved by the use of redundant memory elements provided that the capability for conflict resolution or correction among elements is included 4 1 7 Reporting Requirements The reporting requirements govern all mechanical electromechanical and electronic devices required for voting systems to print audit record entries and results of the tabulation These requirements also address data storage media for transportation of data to other sites 4 1 7 1 Removable Storage Media In voting systems that use storage media that can be removed from the system and transported to another location for readout and report generation these media shall use devices with demonstrated error-free retention for a period of 22 months under the 92 Voting System Performance Guidelines 4 Hardware Requirements environmental conditions for operation and non-operation contained in Subsection 4 1 2 Examples of removable storage media include programmable read-only memory PROM random access memory RAM with battery backup magnetic media or optical media 4 1 7 2 Printers All printers used to produce reports of the vote count shall be capable of producing a Alphanumeric headers b Election office and issue labels c Alphanumeric entries generated as part of the audit record 4 1 8 Vote Data Management Requirements The vote data management requirements for all systems address capabilities that manage process and report voting data after the data has been consolidated at the polling place or other jurisdictional levels These capabilities allow the system to o Consolidate voting data from polling place data memory or transfer devices o Report polling place summaries o Process absentee ballots data entered manually and administrative ballot definition data The requirements address all hardware and software required to generate output reports in the various formats required by the using jurisdiction 4 1 8 1 Data File Management All voting systems shall provide the capability to a Integrate voting data files with ballot definition files b Verify file compatibility c Edit and update files as required 4 1 8 2 Data Report Generation All voting systems shall include report generators for producing output reports at the device polling place and summary level with provisions for administrative and judicial subdivisions as required by the using jurisdiction 93 Voting System Performance Guidelines 4 Hardware Requirements 4 2 Physical Characteristics This subsection covers physical characteristics of all voting systems and components that affect their general utility and suitability for election operations 4 2 1 Size There is no numerical limitation on the size of any voting equipment but the size of each voting machine should be compatible with its intended use and the location at which the equipment is to be used 4 2 2 Weight There is no numerical limitation on the weight of any voting equipment but the weight of each voting machine should be compatible with its intended use and the location at which the equipment is to be used 4 2 3 Transport and Storage of Precinct Systems All precinct voting systems shall a Provide a means to safely and easily handle transport and install voting equipment such as wheels or a handle or handles b Be capable of using or be provided with a protective enclosure rendering the equipment capable of withstanding i Impact shock and vibration loads associated with surface and air transportation ii Stacking loads associated with storage 4 3 Design Construction and Maintenance Characteristics This subsection covers voting system materials construction workmanship and specific design characteristics important to the successful operation and efficient maintenance of the voting system 4 3 1 Materials Processes and Parts The approach to system design is unrestricted and may incorporate any form or variant of technology capable of meeting the voting systems requirements and standards 94 Voting System Performance Guidelines 4 Hardware Requirements Precinct count systems shall be designed in accordance with best commercial practice for microcomputers process controllers and their peripheral components Central count voting systems and equipment used in a central tabulating environment shall be designed in accordance with best commercial and industrial practice All voting systems shall a Be designed and constructed so that the frequency of equipment malfunctions and maintenance requirements are consistent with the reliability requirements of Section 4 3 3 and are furthermore reduced to the lowest levels consistent with cost constraints b Include as part of the accompanying Technical Data Package an approved parts list c Exclude parts or components not included in the approved parts list 4 3 2 Durability All voting systems shall be designed to withstand normal use without deterioration and without excessive maintenance cost for a period of ten years 4 3 3 Reliability 4 3 3 1 Terms The following terms are used as defined in Appendix A failure critical failure userserviceable failure non-user-serviceable failure 4 3 3 2 Use case informative The August 31 2007 draft of VVSG Recommendations to the EAC included a detailed use case in the derivation of benchmarks that were expressed in terms of failures per unit of volume Failures were divided into three categories user-serviceable non-userserviceable and disenfranchisement Disenfranchisement defined as any failure that results in all cast vote records pertaining to a given ballot becoming unusable or that makes it impossible to determine whether or not a ballot was cast was assigned a benchmark of zero i e can't happen For the other two categories limits were determined for the number of such failures that would be tolerated in an election e g by substituting spare equipment and benchmarks were derived based on a 1 % risk of exceeding those limits The following table summarizes significant estimates derived from the VVSG Recommendations use case The estimates for accessible voting stations Acc-VS have 95 Voting System Performance Guidelines 4 Hardware Requirements been adjusted to reflect the fact that Acc-VS may be deployed at the rate of one per polling place in jurisdictions where the remainder of the voting volume is handled with manually-marked paper ballots resulting in more stringent reliability requirements for the Acc-VS The VVSG Recommendations instead assumed that they would always be deployed in numbers sufficient for all voters to use them which has not been the case Device class Population including spares EMS Central tabulator Precinct tabulator Accessible voting station Acc-VS Other electronic vote-capture device Activation device Activation media token e g smart card 1 9 61 61 606 61 1236 Manageable number of non-userserviceable failures 0 1 1 1 6 1 36 Manageable number of userserviceable failures 2 N A 3 3 18 N A N A 4 3 3 3 Basis of requirements informative Benchmarks in the next section are derived from the VVSG Recommendations use case Specific benchmarks cannot be reused from the VVSG Recommendations because the metric has changed from failures per unit of volume to the probability of failure in an election Manufacturers are now required to apply best practices to assure reliability In the manufacturer's reliability analysis each specific individual identified failure mode would be assigned a probability and the system probability of failure would then be derived mathematically As a trivial example if a device has only two failure modes each has probability 0 01 of occurring and they are independent of one another the probability of failure is 1 - 0 992 0 0199 Since the underlying probabilities are likely to depend on the volume that a device is expected to handle in the course of the election minimum values for the assumed volume per device per election from Table 6-1 of the VVSG Recommendations are specified in a requirement The category of critical failures is used in lieu of disenfranchisement It is not possible for a reliability analysis to yield a failure probability of zero so for the critical failures benchmark a very low probability 10-6 is used instead Note that probabilities on the order of 10-9 are used in civil aviation For other benchmarks the VVSG Recommendations' 1 % level of risk for exceeding the manageable number of failures is retained Given N devices each with independent probability of failure p the probability of n or more of them failing in the same election is given by the Binomial probability sum 96 Voting System Performance Guidelines 4 Hardware Requirements N N P p x 1 - p N - x 1-binocdf n-1 N p x n x Determining values of p that limit P to 1 % for each combination of n and N in the previous table is straightforward except for EMS Tolerance of multiple failures per election per EMS cannot be expressed in the terms of the metric used here Instead the benchmark is set to the value such that if there were two EMSs the probability of both of them failing in a given election would be 1 % Since the types of failures identified form a hierarchy of impact--i e a non-userserviceable failure automatically causes as much trouble as a user-serviceable failure and then some--additive probabilities are used for the lower-rank benchmarks Using this approach the meaningless question of whether a critical failure is user-serviceable or not has no impact on the results and need never arise 4 3 3 4 Requirements a The manufacturer shall assure the reliability of the voting system by applying best practices for reliability engineering practices and standard reliability analysis methods e g failure modes and effects analysis FMEA b Letting FC be the set of critical failure modes FN the set of non-user-serviceable failure modes and FS the set of user-serviceable failure modes voting devices shall satisfy the following limits on the probabilities of failures per election Device class Probability of critical failure FC EMS or election results reporting device Central tabulator Precinct tabulator Accessible voting station Acc-VS Other electronic vote-capture device Activation device Activation media token e g smart card 10-6 10-6 10-6 10-6 10-6 10-6 10-6 Probability of critical or non-userserviceable failure FC FN 10-6 0 01735 0 002452 0 002452 0 003856 0 002452 0 01978 Probability of failure FC FN FS 0 1 0 01735 0 01374 0 01374 0 01718 0 002452 0 01978 c In calculating the probabilities of failures the assumed volume per device per election shall be no less than the maximum tabulation rate times 8 hours for a central tabulator 2000 ballots for a precinct tabulator 2000 ballot activations for an activation device 480 transactions for an EMS 70 voting sessions for an EBM or 200 voting sessions for any other electronic vote-capture device including DREs 97 Voting System Performance Guidelines 4 Hardware Requirements d If a voting device combines functions of more than one of the device classes listed in the previous requirements such as a DRE that also accumulates and reports election results uploaded from other devices its performance of these different functions shall satisfy the respective benchmarks In the event that two different benchmarks would apply to the same function the more stringent benchmark lower probability higher volume shall prevail 4 3 4 Product Marking All voting systems shall a Display on each device a separate data plate containing a schedule for and list of operations required to service or to perform preventive maintenance b Display advisory caution and warning instructions to ensure safe operation of the equipment and to avoid exposure to hazardous electrical voltages and moving parts at all locations where operation or exposure may occur 4 3 5 Workmanship To help ensure proper workmanship all manufacturers of voting systems shall a Adopt and adhere to practices and procedures to ensure that their products are free from damage or defect that could make them unsatisfactory for their intended purpose b Ensure that components provided by external suppliers are free from damage or defect that could make them unsatisfactory for their intended purpose 4 3 6 Safety a All voting systems shall meet the following requirements for safety i All voting systems and their components shall be designed to eliminate hazards to personnel or to the equipment itself ii Defects in design and construction that can result in personal injury or equipment damage shall be detected and corrected before voting systems and components are placed into service iii Equipment design for personnel safety shall be equal to or better than the appropriate requirements of the Occupational Safety and Health Act Code of Federal Regulations Title 29 Part 1910 b In order to meet these safety requirements voting system manufacturers shall submit their systems for review to a Nationally Recognized Testing Laboratory NRTL 98 Voting System Performance Guidelines 4 Hardware Requirements Discussion NRTL laboratories are specifically accredited by OSHA to identify relevant safety standards for a product and to conduct testing that ensures specific products meet the requirements of the product safety standards identified Although this standard does not require that a voting system carry a Product Safety Listing Label voting system manufacturers may voluntarily choose to implement such labeling in order to meet such requirements implemented by State or local election jurisdictions EAC accredited VSTLs remain responsible for non-core testing performed by third party laboratories as noted in Section 2 of the EAC Voting System Test Laboratory Program Manual Version 1 0 14 14 The italicized text in Section 4 3 6 is based on EAC Decision on the Request for Interpretation 2008-09 http www eac gov assets 1 Page EAC%20Decision%20on%20Safety%20Testing pdf 99 5 Software Requirements Table of Contents 5 5 1 5 2 5 2 1 5 2 2 5 2 3 5 2 4 5 2 5 5 2 6 5 2 7 5 2 8 5 3 5 4 5 4 1 5 4 2 5 4 3 5 4 4 5 5 Software Requirements Software Configuration Software Design and Coding Standards Scope Selection of programming languages Selection of general coding standard Software modularity and programming Structured programming Header comments Executable code and data integrity Error checking Data and Document Retention Audit Record Data Pre-election Audit Records System Readiness Audit Records In-process Audit Records Vote Tally Data Vote Secrecy on DRE and EBM Systems 101 101 101 101 102 103 104 105 108 109 110 112 113 113 113 114 115 115 Voting System Performance Guidelines 5 Software Requirements 5 Software Requirements 5 1 Software Configuration Configuration of software both operating systems and applications is critical to proper system functioning Correct test design and sufficient test execution must account for the intended and proper configuration of all system components a Therefore the manufacturers shall submit a record of all user selections made during software installation as part of the Technical Data Package b The manufacturer shall also submit a record of all configuration changes made to the software following its installation c The VSTL shall confirm the propriety and correctness of these user selections and configuration changes 5 2 Software Design and Coding Standards This section describes essential design and performance characteristics of the logic used in voting systems The requirements of this section are intended to ensure that voting system logic is reliable robust testable and maintainable The general requirements of this section apply to logic used to support the entire range of voting system activities Although this section emphasizes software the standards described also influence hardware design considerations While there is no best way to design logic the use of outdated and ad hoc practices is a risk factor for unreliability unmaintainability etc Consequently these guidelines require the use of modern programming practices The use of widely recognized and proven logic design methods will facilitate the analysis and testing of voting system logic 5 2 1 Scope The terms application logic border logic third-party logic configuration data and COTS are defined in Appendix A and are used carefully in this section to specify the applicability of requirements The requirements of this section that constrain programming practices--design requirements--apply to all application logic regardless of the ownership of the logic or the ownership and location of the hardware on which the logic is installed or operates Although it would be desirable for COTS software to conform to the design requirements on software workmanship its conformity to those requirements could not be assessed without access to the source code hence the design requirements are scoped to exclude 101 Voting System Performance Guidelines 5 Software Requirements COTS software In contrast requirements that can be tested without access to source code such as the requirement to detect and respond to invalid input without crashing 5 2 8 a apply to COTS software in exactly the same way as they apply to non-COTS software a Regardless of its source software firmware or hardwired logic that has been modified for use in voting systems or has no application other than in voting systems shall not be deemed COTS b Third-party logic border logic and configuration data are not required to conform to the design requirements on software workmanship but manufacturers shall supply that source code and data to the VSTL to enable a complete review of the application logic Notably the distinction between software firmware and hardwired logic does not impact the level of scrutiny that a component receives nor are the requirements applying to application logic relaxed in any way if that logic is realized in firmware or hardwired logic instead of software The following table summarizes the scoping considerations for software requirements and testing CATEGORIES LEVEL OF SCRUTINY SOURCE TESTED CODE DATA REQUIRED CODING STANDARDS ENFORCED COTS Black-box Yes No No third-party logic border logic configuration data White-box Yes Yes No application logic Coding standards Yes Yes Yes 5 2 2 Selection of programming languages Application logic shall be produced in a high-level programming language that has all of the following control constructs a b c d e Sequence Loop with exit condition e g for while do-loops and or for each If Then Else conditional Case conditional and Block-structured exception handling e g try throw catch The intent of this requirement is clarified in Volume I Section 5 2 5 with discussion and examples of specific programming languages 102 Voting System Performance Guidelines 5 Software Requirements By excluding border logic this requirement allows the use of assembly language for hardware-related segments such as device controllers and handler programs It also allows the use of an externally-imposed language for interacting with an Application Program Interface API or database query engine However the special code should be insulated from the bulk of the code e g by wrapping it in callable units expressed in the prevailing language to minimize the number of places that special code appears C f MISRA-C 2004 15 Rule 2 1 Assembly language shall be encapsulated and isolated Acceptable programming languages are also constrained by Requirements 5 2 7 a iii and iv which effectively prohibit the invention of new languages The above requirement may be satisfied by using COTS extension packages to add missing control constructs to languages that could not otherwise conform For example C11 16 does not support block-structured exception handling but the construct can be retrofitted using e g except 17 or another COTS package The use of non-COTS extension packages or manufacturer-specific code for this purpose is not acceptable as it would place an unreasonable burden on the VSTL to verify the soundness of an unproven extension effectively a new programming language The package must have a proven track record of performance supporting the assertion that it would be stable and suitable for use in voting systems just as the compiler or interpreter for the base programming language must 5 2 3 Selection of general coding standard Note The requirements of this section attempt to clarify the published reviewed and industry-accepted language appearing in previous iterations of the Guidelines but the intent of the requirements is unchanged a Application logic shall adhere to a published credible set of coding rules conventions or standards herein simply called the coding standard that enhance the workmanship security integrity testability and maintainability of applications Coding standards that are excessively specialized or simply inadequate may be rejected on the grounds that they do not enhance one or more of workmanship security integrity testability and maintainability b Coding standards shall be considered published if and only if they appear in a publicly available book magazine journal or new media with analogous circulation and availability or if they are publicly available on the Internet Following are examples of published coding standards links valid as of 201204-05 These are only examples and are not necessarily the best available for the purpose 15 MISRA-C 2004 Guidelines for the use of the C language in critical systems MIRA Limited U K 2004-10 16 ISO IEC 9899 2011 Programming languages--C Available from ISO http www iso org 17 CEXCEPT exception handling in C software package 2000 Available at http cexcept sourceforge net 103 Voting System Performance Guidelines 5 Software Requirements Ada Ada Quality and Style Guide Guidelines for Professional Programmers http en wikibooks org wiki Ada_Style_Guide C CERT C Coding Standard CERT Software Engineering Institute Carnegie Mellon University Content available at https www securecoding cert org confluence display cplusplus Introduction C# C# C# Coding Conventions C# Programming Guide Microsoft http msdn microsoft com en-us library ff926074 aspx plus Framework Design Guidelines Microsoft http msdn microsoft com enus library ms229042 aspx Java Java Coding Guidelines CERT Software Engineering Institute Carnegie Mellon University https www securecoding cert org confluence display java Java Coding Guid elines c Coding standards shall be considered credible if and only if at least two different organizations with no ties to the creator of the rules or to the manufacturer seeking conformity assessment and which are not themselves voting equipment manufacturers independently decided to adopt them and made active use of them at some time within the three years before conformity assessment was first sought Coding standards evolve and it is desirable for voting systems to be aligned with modern practices If the three year rule was satisfied at the time that a system was first submitted for testing it is considered satisfied for the purpose of subsequent reassessments of that system However new systems must meet the three year rule as of the time that they are first submitted for testing even if they reuse parts of older systems 5 2 4 Software modularity and programming a Application logic shall be designed in a modular fashion Each module shall have a specific function that can be tested and verified independently of the remainder of the code In practice some additional modules such as library modules may be needed to compile the module under test but the modular construction allows the supporting modules to be replaced by special test versions that support test objectives b Callable units shall have cyclomatic complexity 18 less than 20 18 T McCabe A Complexity Measure IEEE Transactions on Software Engineering Vol SE-2 No 4 pp 308-320 December 1976 104 Voting System Performance Guidelines 5 Software Requirements 5 2 5 Structured programming Specific programming languages are identified to support the discussion In no case does such identification imply recommendation or endorsement nor does it imply that the programming languages identified are necessarily the best or only languages acceptable for voting system use Concept Sequence Loop with exit condition If Then Else conditional Case conditional VSS 19 20 Visual Basic 2005 Ada 22 23 C 24 25 C 26 27 C# 28 29 Java 30 31 VVSG 21 VB 8 0 32 Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Named block exit No Block-structured No exception handling Yes No No No Yes No 33 Yes No Yes Yes Yes Yes The requirement to follow a coding standard serves two purposes First by requiring specific risk factors to be mitigated coding standards support integrity and maintainability of voting system logic Second by making the logic more transparent to a 19 Performance and Test Standards for Punchcard Marksense and Direct Recording Electronic Voting Systems January 1990 edition with April 1990 revisions in Voting System Standards U S Government Printing Office 1990 Available at http josephhall org fec_vss_1990_pdf 1990_VSS pdf 20 2002 Voting Systems Standards available from http www eac gov testing_and_certification voluntary_voting_system_guidelines aspx 21 2005 Voluntary Voting System Guidelines Version 1 0 2006-03-06 available from http www eac gov testing_and_certification voluntary_voting_system_guidelines aspx 22 ISO IEC 8652 1987 Programming languages--Ada 23 ISO IEC 8652 1995 Information technology--Programming languages--Ada Available from ISO http www iso org 24 ISO IEC 9899 1990 Programming languages--C 25 ISO IEC 9899 1999 Programming languages--C Available from ISO http www iso org 26 ISO IEC 14882 1998 Programming languages--C 27 ISO IEC 14882 2003 Programming languages--C Available from ISO http www iso org 28 ISO IEC 23270 2003 Information technology--C# language specification 29 ISO IEC 23270 2006 Information technology--Programming languages--C# Available from ISO http www iso org 30 The Java Language Specification Third Edition 2005 Available at http docs oracle com javase specs 31 The Java Language Specification Java SE 7 Edition 2011 Available at http docs oracle com javase specs 32 Paul Vick The Microsoft R Visual Basic R Language Specification Version 8 0 2005 Available from Microsoft Download Center http go microsoft com fwlink linkid 62990 33 Visual Basic 8 does not support named block exit but it does support specifying the kind of block do loop for loop while loop select subroutine function etc from which to exit which need not be the innermost block 105 Voting System Performance Guidelines 5 Software Requirements reviewer coding standards facilitate VSTL evaluation of the logic's correctness to a level of assurance beyond that provided by operational testing Prominent among the requirements addressing logical transparency is the requirement to use high-level control constructs and to refrain from using the low-level arbitrary branch a k a goto As is reflected in the above table most high-level concepts for control flow were established by the time the first edition of the Guidelines was published and are supported by all of the programming languages that were examined as probable candidates for voting system use as of this iteration However two additional concepts have been slower to gain universal support The first additional concept called here the named block exit is the ability to exit a specific block from within an arbitrary number of nested blocks as opposed to only being able to exit the innermost block without resorting to goto The absence of named block exit from some languages is not cause for concern here because deeply nested blocks are themselves detrimental to the transparency of logic and most coding standards encourage restructuring them into separate callable units The second additional concept called here block-structured exception handling is the ability to associate exception handlers with blocks of logic and implicitly the presence of the exception concept in the programming language This simply means try throw catch or equivalent statements and should not be confused with the specific implementation known as Structured Exception Handling SEH 34 Unlike deeply nested blocks exceptions cannot be eliminated by restructuring logic When exceptions are not used the errors cannot be handled but their existence is not avoided 35 Previous Guidelines required voting systems to handle such errors by some means preferably using programming language exceptions 2005 VVSG I 5 2 3 e but there was no unambiguous requirement for the programming language to support exception handling These Guidelines require programming language exceptions because without them the programmer must check for every possible error condition in every possible location which both obfuscates the application logic and creates a high likelihood that some or many possible errors will not be checked for Additionally these Guidelines require block-structured exception handling because like all unstructured programming unstructured exception handling obfuscates logic and makes its verification by the VSTL more difficult One of the major difficulties of conventional defensive programming is that the fault tolerance actions are inseparably bound in with the normal processing which the design is to provide This can significantly increase design complexity and consequently can compromise the reliability and maintainability of the software 36 Existing voting system logic implemented in programming languages that do not support block-structured exception handling can be brought into compliance either through migration to a newer programming language most likely a descendant of the same 34 Matt Pietrek A Crash Course on the Depths of Win32 TM Structured Exception Handling Microsoft Systems Journal 1997-01 Available at http www microsoft com msj 0197 exception exception aspx 35 ISO IEC TR 15942 2000 Information technology--Programming languages--Guide for the use of the Ada programming language in high integrity systems Available from ISO http www iso org 36 M R Moulding Designing for high integrity the software fault tolerance approach Section 3 4 In C T Sennett ed High-Integrity Software Plenum Press New York and London 1989 106 Voting System Performance Guidelines 5 Software Requirements language that would require minimal changes or through the use of a COTS package that retrofits block-structured exception handling onto the previous language with minimal changes While the latter path may at first appear to be less work it should be noted that many library functions may need to be adapted to throw exceptions when exceptional conditions arise whereas in a programming environment that had exceptions to begin with the analogous library functions would already do this see Requirement a below a Application logic shall handle exceptions using block-structured exception handling constructs If application logic makes use of any COTS or third-party logic callable units that do not throw exceptions when exceptional conditions occur those callable units shall be wrapped in callable units that check for the relevant error conditions and translate them into exceptions and the remainder of application logic shall use only the wrapped version For example if an application written in C99 cexcept used the malloc function of libc which returns a null pointer in case of failure instead of throwing an exception the malloc function would need to be wrapped Here is one possible implementation void checkedMalloc size_t size void ptr malloc size if ptr Throw bad_alloc return ptr #define malloc checkedMalloc Wrapping legacy functions avoids the need to check for errors after every invocation which both obfuscates the application logic and creates a high likelihood that some or many possible errors will not be checked for In C it would be preferable to use one of the newer mechanisms that already throw exceptions on failure and avoid use of legacy functions altogether b Application logic shall contain no unstructured control constructs i Arbitrary branches a k a gotos are prohibited ii Exceptions shall only be used for abnormal conditions Exceptions shall not be used to redirect the flow of control in normal non-exceptional conditions Intentional exceptions cannot be used as a substitute for arbitrary branch Normal expected events such as reaching the end of a file that is being read from beginning to end or receiving invalid input from a user interface are not exceptional conditions and shall not be implemented using exception handlers iii Unstructured exception handling e g On Error GoTo setjmp longjmp or explicit tests for error conditions after every executable statement is prohibited The internal use of such constructs by a COTS extension package that adds block-structured exception handling to a programming language that otherwise would not have it as described in Requirement a is allowed Analogously it is not a problem that source code written in a high-level programming language is compiled into low-level machine code that contains arbitrary branches It is only the direct use of low-level constructs in application logic that presents a problem 107 Voting System Performance Guidelines 5 Software Requirements c Application logic shall not compile or interpret configuration data or other input data as a programming language Distinguishing what is a programming language from what is not requires some professional judgment However in general sequential execution of imperative instructions is a characteristic of conventional programming languages that should not be exhibited by configuration data Configuration data must be declarative or informative in nature not imperative For example it is permissible for configuration data to contain a template that informs a report generating application as to the form and content of a report that it should generate but it is not permissible for configuration data to contain instructions that are executed or interpreted to generate a report essentially embedding the logic of the report generator inside the configuration data The reasons for this requirement are 1 mingling code and data is bad design and 2 embedding logic within configuration data is an evasion of the conformity assessment process for application logic 5 2 6 Header comments Header comments and other commenting standards should be specified by the selected coding standard in a manner consistent with the idiom of the programming language chosen If the coding standard specifies a coding style and commenting standard that make header comments redundant then they may be omitted Otherwise in the event that the coding standard fails to specify the content of header comments application logic modules should include header comments that provide at least the following information for each callable unit function method operation subroutine procedure etc a The purpose of the unit and how it works if not obvious b A description of input parameters outputs and return values exceptions thrown and side-effects c Any protocols that must be observed e g unit calling sequences d File references by name and method of access read write modify append etc e Global variables used if applicable f Audit event generation g Date of creation and h Change log revision record Change logs need not cover the nascent period but they must go back as far as the first baseline or release that is submitted for testing and should go back as far as the first baseline or release that is deemed reasonably coherent 108 Voting System Performance Guidelines 5 Software Requirements 5 2 7 Executable code and data integrity 37 a Subrequirements i through iv apply to application logic and only to application logic i Self-modifying code is prohibited ii Application logic shall be free of race conditions deadlocks livelocks and resource starvation iii If compiled code is used it shall only be compiled using a COTS compiler This prohibits the use of arbitrary nonstandard compilers and consequently the invention of new programming languages iv If interpreted code is used it shall only be run under a specific identified version of a COTS runtime interpreter This ensures 1 that no arbitrary nonstandard interpreted languages are used and 2 that the software tested and approved during the conformity assessment process does not change behavior because of a change to the interpreter b All programmed devices shall prevent replacement or modification of executable or interpreted code e g by other programs on the system by people physically replacing the memory or medium containing the code or by faulty code except where this access is necessary to prepare authorized software and equipment for use This requirement may be partially satisfied through a combination of read-only memory ROM the memory protection implemented by most popular COTS operating systems error checking as described in Volume I Section 5 2 8 and access and integrity controls c All voting devices shall prevent access to or manipulation of configuration data vote data or audit records e g by physical tampering with the medium or mechanism containing the data by other programs on the system or by faulty code except where this access is necessary to conduct the voting process This requirement may be partially satisfied through a combination of the memory protection implemented by most popular COTS operating systems error checking as described in Volume I Section 5 2 8 and access and integrity controls Systems using mechanical counters to store vote data must protect the counters from tampering If vote data are stored on paper the paper must be protected from tampering Modification of audit records after they are created is never necessary d All programmed devices shall provide the capability to monitor the transfer quality of I O operations reporting the number and types of errors that occur and how they were corrected e Application logic and border logic shall contain no inaccessible code dead code other than defensive code including exception handlers that is provided to defend against the occurrence of failures and can't happen conditions 37 Portions of this section are derived from Section 5 6 2 2 of IEEE Draft Standard for the Evaluation of Voting Equipment draft P1583 D5 3 2b 2005-01-04 This material is from an unapproved draft of a proposed IEEE Standard P1583 As such the material is subject to change in the final standard Because this material is from an unapproved draft the IEEE recommends that it not be utilized for any conformance compliance purposes It is used at your own risk 109 Voting System Performance Guidelines 5 Software Requirements 5 2 8 Error checking 38 This section contains requirements for application logic to avoid detect and prevent well-known types of errors that could compromise voting integrity and security Additional advice from the security perspective is available at the CERT R Coordination Center Secure Coding homepage http www cert org secure-coding and related sites esp Department of Homeland Security Build Security In homepage https buildsecurityin us-cert gov a All programmed devices shall check information inputs whether from manual entry or other external source for completeness and validity and ensure that incomplete or invalid inputs do not lead to irreversible error i At any point where it is possible for a user voter poll worker etc to enter a scalar or enumerated type value that is outside the range of values that is valid in the context of the device's logic that input shall be range-checked This applies to inputs of values of numeric types character types temporal types and any other types for which the concept of range is well-defined ii At any point where it is possible for a user to enter a character string or list of values that is longer than the maximum or shorter than the minimum length that is valid in the context of the device's logic that input shall be length-checked iii The device shall respond to an invalid input by notifying the user of the error and enabling the user to correct the erroneous input before consequential errors and or loss of program integrity occur b All application logic that is vulnerable to the following types of errors shall check for these errors at run time and respond defensively as specified by Requirement f when they occur 1 out-of-bounds accesses of arrays or strings includes buffers used to move data 2 stack overflow errors 3 CPU-level exceptions such as address and bus errors dividing by zero and the like 4 variables that are not appropriately handled when out of expected boundaries 5 numeric overflows 6 known programming language specific vulnerabilities i If the application logic uses arrays vectors or any analogous data structures and the programming language does not provide automatic run-time range checking of the indices the indices shall be ranged-checked on every access Range checking code should not be duplicated before each access Clean implementation approaches include 1 consistently using dedicated accessors functions methods operations subroutines procedures etc that range-check the indices 2 defining and consistently using a new data type or class that encapsulates the range-checking logic 3 declaring the array using a template that causes all accessors to be range-checked or 4 declaring the array index to be a data type whose enforced range is matched to the size of the array Range-enforced data types or classes may be 38 Portions of this section are derived from Sections 5 6 2 2 and 6 6 4 2 of IEEE Draft Standard for the Evaluation of Voting Equipment draft P1583 D5 3 2b 2005-01-04 This material is from an unapproved draft of a proposed IEEE Standard P1583 As such the material is subject to change in the final standard Because this material is from an unapproved draft the IEEE recommends that it not be utilized for any conformance compliance purposes It is used at your own risk 110 Voting System Performance Guidelines 5 Software Requirements provided by the programming environment or they may be defined in application logic If acceptable values of the index do not form a contiguous range a map structure may be more appropriate than a vector ii If stack overflow does not automatically result in an exception the application logic shall explicitly check for and prevent stack overflow Embedded system developers use a variety of techniques for avoiding stack overflow Commonly the stack is monitored and warnings and exceptions are thrown when thresholds are crossed In non-embedded contexts stack overflow often manifests as a CPU-level exception related to memory segmentation in which case it can be handled pursuant to Requirement b iii iii The application logic shall implement such handlers as are needed to detect and respond to CPU-level exceptions For example under Unix a CPU-level exception would manifest as a signal so a signal handler is needed If the platform supports it it is preferable to translate CPU-level exceptions into software-level exceptions so that all exceptions can be handled in a consistent fashion within the voting application however not all platforms support it iv All scalar or enumerated type parameters whose valid ranges as used in a callable unit function method operation subroutine procedure etc do not cover the entire ranges of their declared data types shall be range-checked on entry to the unit This applies to parameters of numeric types character types temporal types and any other types for which the concept of range is well-defined In cases where the restricted range is frequently used and or associated with a meaningful concept within the scope of the application the best approach is to define a new class or data type that encapsulates the range restriction eliminating the need for range checks on each use This requirement differs from Requirement a Requirement a deals with user input which is expected to contain errors while this requirement deals with program internal parameters which are expected to conform to the expectations of the designer User input errors are a normal occurrence the errors discussed here are grounds for throwing exceptions v If the programming language does not provide automatic run-time detection of numeric overflow all arithmetic operations that could potentially overflow the relevant data type shall be checked for overflow This requirement should be approached in a manner similar to Requirement b i Overflow checking should be encapsulated as much as possible c All application logic that is vulnerable to the following types of errors should check for these errors at run time and respond defensively as specified by Requirement f when they occur 1 pointer variable errors 2 dynamic memory allocation and management errors i If application logic uses pointers or a similar mechanism for specifying absolute memory locations the application logic should validate pointers or addresses before they are used Improper overwriting should be prevented in general as required by Requirements 5 2 7 b and c Nevertheless even if read-only memory would prevent the overwrite from succeeding an attempted overwrite indicates a logic fault that must be corrected Pointer use that is fully encapsulated within a standard platform library is treated as COTS software 111 Voting System Performance Guidelines 5 Software Requirements d Application logic should be instrumented and or analyzed with a COTS tool for detecting the kinds of errors enumerated in requirements b and c above e If pointers are used any pointer variables that remain within scope after the memory they point to is deallocated shall be set to null or marked as invalid pursuant to the idiom of the programming language used after the memory they point to is deallocated If this is not done automatically by the programming environment a callable unit should be dedicated to the task of deallocating memory and nullifying pointers Equivalently smart pointers like the C std unique_ptr can be used to avoid the problem One should not add assignments after every deallocation in the source code In languages using garbage collection memory is not deallocated until all pointers to it have gone out of scope so this requirement is moot f The detection of any of the errors enumerated in Requirements b and c shall be treated as a complete failure of the callable unit in which the error was detected An appropriate exception shall be thrown and control shall pass out of the unit forthwith g Error checks detailed in Requirements b and c shall remain active in production code These errors are incompatible with voting integrity so masking them is unacceptable Manufacturers should not implement error checks using the C C assert macro It is often disabled sometimes automatically when software is compiled in production mode Furthermore it does not appropriately throw an exception but instead aborts the program h Exceptions resulting from failed error checks or CPU-level exceptions shall require intervention by an election official or administrator before voting can continue These errors are incompatible with voting integrity so masking them is unacceptable i Electronic devices shall include a means of identifying device failure and any corrective action needed j Electronic devices should proactively detect equipment failures and alert an election official or administrator when they occur k Electronic devices shall proactively detect or prevent basic violations of election integrity e g stuffing of the ballot box or the accumulation of negative votes and alert an election official or administrator if they occur Equipment can verify only those conditions that are within the scope of what the equipment does This provides defense-in-depth to supplement procedural controls and auditing practices 5 3 Data and Document Retention All systems shall a Maintain the integrity of voting and audit data during an election and for at least 22 months thereafter a time sufficient to resolve most contested elections and support other activities related to the reconstruction and investigation of a contested election b Protect against the failure of any data input or storage device at a location controlled by the jurisdiction or its contractors and against any attempt at improper data entry or retrieval 112 Voting System Performance Guidelines 5 Software Requirements 5 4 Audit Record Data Audit trails are essential to ensure the integrity of a voting system Operational requirements for audit trails are described in Subsection 2 1 5 1 Audit record data are generated by these procedures The audit record data in the following subsections are essential to the complete recording of election operations and reporting of the vote tally This list of audit records may not reflect the design constructs of some systems Therefore manufacturers shall supplement it with information relevant to the operation of their specific systems 5 4 1 Pre-election Audit Records During election definition and ballot preparation the system shall audit the preparation of the baseline ballot formats and modifications to them a description of these modifications and corresponding dates The log shall include a The allowable number of selections a contest b The combinations of voting patterns permitted or required by the jurisdiction c The inclusion or exclusion of contests as the result of multiple districting within the polling place d Any other characteristics that may be peculiar to the jurisdiction the election or the polling place location e Manual data maintained by election personnel f Samples of all final ballot formats g Ballot preparation edit listings 5 4 2 System Readiness Audit Records The following minimum requirements apply to system readiness audit records a Prior to the start of ballot counting a system process shall verify hardware and software status and generate a readiness audit record This record shall include the identification of the software release the identification of the election to be processed and the results of software and hardware diagnostic tests b In the case of systems used at the polling place the record shall include polling place identification c The ballot interpretation logic shall test and record the correct installation of ballot formats on voting devices d The software shall check and record the status of all data paths and memory locations to be used in vote recording to protect against contamination of voting data e Upon the conclusion of the tests the software shall provide evidence in the audit record that the test data have been expunged 113 Voting System Performance Guidelines 5 Software Requirements f If required and provided the ballot reader and arithmetic-logic unit shall be evaluated for accuracy and the system shall record the results It shall allow the processing or simulated processing of sufficient test ballots to provide a statistical estimate of processing accuracy g For systems that use a public network provide a report of test ballots that includes i Number of ballots sent ii When each ballot was sent iii Machine from which each ballot was sent iv Specific votes or selections contained in the ballot 5 4 3 In-process Audit Records In-process audit records document system operations during diagnostic routines and the casting and tallying of ballots At a minimum the in-process audit records shall contain a Machine generated error and exception messages to demonstrate successful recovery Examples include but are not necessarily limited to i The source and disposition of system interrupts resulting in entry into exception handling routines ii All messages generated by exception handlers iii The identification code and number of occurrences for each hardware and software error or failure iv Notification of system login or access errors file access errors and physical violations of security as they occur and a summary record of these events after processing v Other exception events such as power failures failure of critical hardware components data transmission errors or other types of operating anomalies b Critical system status messages other than informational messages displayed by the system during the course of normal operations These items include but are not limited to i Diagnostic and status messages upon startup ii The zero totals check conducted before opening the polling place or counting a precinct centrally iii For paper-based systems the initiation or termination of optical scanner and communications equipment operation iv For DRE machines at controlled voting locations the event and time if available of activating and casting each ballot i e each voter's transaction as an event This data can be compared with the public counter for reconciliation purposes c Non-critical status messages that are generated by the machine's data quality monitor or by software and hardware condition monitors d System generated log of all normal process activity and system events that require operator intervention so that each operator access can be monitored and access sequence can be constructed 114 Voting System Performance Guidelines 5 Software Requirements 5 4 4 Vote Tally Data In addition to the audit requirements described above other election-related data is essential for reporting results to interested parties the press and the voting public and is vital to verifying an accurate count Voting systems shall meet these reporting requirements by providing software capable of obtaining data concerning various aspects of vote counting and producing printed reports At a minimum vote tally data shall include a Number of ballots cast using each ballot configuration by tabulator by precinct and by political subdivision b Candidate and measure vote totals for each contest by tabulator c The number of ballots read within each precinct and for additional jurisdictional levels by configuration including separate totals for each party in primary elections d Separate accumulation of overvotes and undervotes for each contest by tabulator precinct and for additional jurisdictional levels no overvotes would be indicated for DRE voting devices e For paper-based systems only the total number of ballots both able to be processed and unable to be processed and if there are multiple card ballots the total number of cards read For systems that produce an electronic file containing vote tally data the contents of the file shall include the same minimum data cited above for printed vote tally reports 5 5 Vote Secrecy on DRE and EBM Systems All DRE and EBM systems shall ensure vote secrecy by a Immediately after the ballot is recorded to persistent electronic storage or printed erasing the selections from the device's display working memory and all other storage including all forms of temporary storage b Immediately after the voter chooses to cancel his or her ballot erasing the selections from the display and all other storage including buffers and other temporary storage 115 6 Telecommunications Requirements Table of Contents 6 6 1 6 1 1 6 1 2 6 1 3 6 2 6 2 1 6 2 2 6 2 3 6 2 4 6 2 5 Telecommunications Requirements Scope Types of Components Telecommunications Operations and Providers Data Transmission Design Construction and Maintenance Requirements Accuracy Durability Reliability Integrity Confirmation 117 117 118 118 119 120 120 120 120 120 121 Voting System Performance Guidelines 6 Telecommunications Requirements 6 Telecommunications Requirements 6 1 Scope This section contains the performance design and maintenance characteristics of the telecommunications components of voting systems and the acceptable levels of performance against these characteristics For the purpose of the Guidelines telecommunications is defined as the capability to transmit and receive data electronically using hardware and software components over distances both within and external to a polling place The requirements in this section represent acceptable levels of combined telecommunications hardware and software function and performance for the transmission of data that is used to operate the system and report election results Where applicable this section specifies minimum values for critical performance and functional attributes involving telecommunications hardware and software components This section does not apply to other means of moving data such as the physical transport of data recorded on paper-based media or the transport of physical devices such as memory cards that store data in electronic form Voting systems may include network hardware and software to transfer data among systems Major network components are local area networks LANs wide area networks WANs workstations desktop computers servers data and applications Workstations include voting stations precinct tabulation systems and voting supervisory terminals Servers include systems that provide registration forms and ballots and accumulate and process voter registrations and cast ballots Desirable network characteristics include simplicity flexibility especially in routing to maintain good response times and maintainability including availability provided primarily through redundancy of resources and connections particularly of connections to public infrastructure A wide area network WAN public telecommunications component consists of the hardware and software to transport information over shared public i e commercial or governmental circuitry or among private systems For voting systems the telecommunications boundaries are defined as the transport circuitry on one side of which exists the public telecommunications infrastructure outside the control of voting system supervisors On the other side of the transport circuitry are the local area network LAN resources workstations servers data and applications controlled by voting system supervisors Local area network LAN components consist of the hardware and software infrastructure used to transport information between users in a local environment 117 Voting System Performance Guidelines 6 Telecommunications Requirements typically a building or group of buildings Typically a LAN connects workstations with a local server An application may be a single program or a group of programs that work together to provide a function to an end user who may be a voter or an election administrator Voter programs may include voter registration balloting and status checking Administrator programs may include ballot preparation registration for preparation registration approval ballot vetting ballot processing and election processing This section is intended to complement the network security requirements found in Section 7 which include requirements for voter and administrator access availability of network service data confidentiality and data integrity Most importantly security services must restrict access to local election system components from public resources and these services must also restrict access to voting system data while it is in transit through public networks 6 1 1 Types of Components This section addresses telecommunications hardware and software across a broad range of technologies including but not limited to o Dial-up communications technologies including standard landline wireless microwave Very Small Aperture Terminal Integrated Services Digital Network Digital Subscriber Line o Public and private high-speed telecommunications lines including FT-1 T-1 T-3 frame relay private line o Cabling technologies including Universal Twisted Pair cable CAT 5 or higher or Ethernet hub switch o Wireless including radio frequency and infrared o Communications routers o Modems whether internal and external to personal computers servers and other voting system components installed at the polling place or central count location o Modem drivers dial-up networking software o Channel service units and Data service units installed at the polling place or central count location o Dial-up networking applications software 6 1 2 Telecommunications Operations and Providers This section applies to voting-related transmissions over public networks such as those provided by local distribution and long distance carriers This section also applies to private networks regardless of whether the network is owned and operated by the election jurisdiction 118 Voting System Performance Guidelines 6 Telecommunications Requirements For systems that transmit official data over public networks this section applies to telecommunications components installed and operated at locations supervised by election officials such as polling places or central offices This includes o Components acquired by the jurisdiction for the purpose of voting including components installed at the polling place or a central office including central site facilities operated by manufacturers or contractors o Components acquired by others such as school systems libraries military installations and other public organizations that are used at locations supervised by election officials including minimum configuration components required by the manufacturer but that the manufacturer permits to be acquired from third party sources not under the manufacturer's control e g router or modem card manufacturer or supplier 6 1 3 Data Transmission These requirements apply to the use of telecommunications to transmit data for the preparation of the system for an election the execution of an election and the preservation of the system data and audit trails during and following an election While this section does not assume a specific model of voting system operations and does not assume a specific model for the use of telecommunications to support such operations it does address the following types of data where applicable Voter Authentication Coded information that confirms the identity of a voter for security purposes for a system that transmits votes individually over a public network Ballot Definition Information that describes to a voting machine the content and appearance of the ballots to be used in an election Vote Transmission to Central Site For voting systems that transmit votes individually over a public network the transmission of a vote or votes to the county or contractor for consolidation with other vote data Vote Count Information representing the tabulation of votes at any level within the control of the jurisdiction such as the polling place precinct or central count List of Voters A listing of the individual voters who have cast ballots in a specific election Additional data transmissions used to operate a voting system in the conduct of an election but not explicitly listed above are also subject to the requirements of this section For systems that transmit data using public networks this section applies to telecommunications hardware and software for transmissions within and among all combinations of senders and receivers located at polling places precinct count facilities and central count facilities whether operated by the jurisdiction or a contractor 119 Voting System Performance Guidelines 6 Telecommunications Requirements 6 2 Design Construction and Maintenance Requirements Design construction and maintenance requirements for telecommunications represent the operational capability of both system hardware and software These capabilities shall be considered basic to all data transmissions 6 2 1 Accuracy The telecommunications components of all voting systems shall meet the accuracy requirements of Subsection 4 1 1 6 2 2 Durability The telecommunications components of all voting systems shall meet the durability requirements of Subsection 4 3 2 6 2 3 Reliability The telecommunications components of all voting systems shall meet the reliability requirements of Subsection 4 3 3 6 2 4 Integrity For WANs using public telecommunications boundary definition and implementation shall meet the requirements below a Outside service providers and subscribers of such providers shall not be given direct access or control of any resource inside the boundary b Voting system administrators shall not require any type of control of resources outside this boundary Typically an end point of a telecommunications circuit will be a subscriber termination on a Digital Service Unit Customer Service Unit although the specific technology configuration may vary Regardless of the technology used the boundary point must ensure that everything on the voting system side is locally configured and controlled by the election jurisdiction while everything on the public network side is controlled by an outside service provider c The system shall be designed and configured such that it is not vulnerable to a single point of failure in the connection to the public network which could cause total loss of voting capabilities at any polling place 120 Voting System Performance Guidelines 6 Telecommunications Requirements 6 2 5 Confirmation Confirmation occurs when the system notifies the user of the successful or unsuccessful completion of the data transmission where successful completion is defined as accurate receipt of the transmitted data a To provide confirmation the telecommunications components of a voting system shall notify the user of the successful or unsuccessful completion of the data transmission b In the event of unsuccessful transmission the user shall be notified of the action to be taken 121 7 Security Requirements Table of Contents 7 7 1 7 1 1 7 1 2 7 2 7 2 1 7 2 2 7 2 3 7 2 4 7 3 7 3 1 7 3 2 7 4 7 4 1 7 4 2 7 4 3 7 4 4 7 4 5 7 4 6 7 5 7 5 1 7 5 2 7 5 3 7 5 4 7 5 5 7 6 7 6 1 7 6 2 7 7 7 7 1 7 7 2 7 7 3 7 7 4 7 7 5 7 8 7 8 1 7 8 2 7 8 3 7 8 4 Security Requirements Scope Elements of Security Outside Manufacturer Control Organization of This Section Access Control General Access Control Access Control Identification Access Control Authentication Access Control Authorization Physical Security Measures Polling Place Security Central Count Location Security Software Security Software and Firmware Installation Protection Against Malicious Software Software Distribution and Setup Validation Software Distribution Software Reference Information Software Setup Validation Telecommunications and Data Transmission Maintaining Data Integrity Protection Against External Threats Monitoring and Responding to External Threats Shared Operating Environment Election Returns Use of Public Communications Networks Data Transmission Casting Individual Ballots Wireless Communications Controlling Usage Identifying Usage Protecting Transmitted Data Protecting the Wireless Path Protecting the Voting System Voter Verifiable Paper Audit Trail Requirements Display and Print a Paper Record Approve or Void the Paper Record Electronic and Paper Record Structure Equipment Security and Reliability 122 124 124 125 125 126 127 127 127 129 129 129 130 130 130 131 131 131 132 132 135 135 136 136 137 137 138 138 138 139 140 141 142 143 143 144 144 145 145 148 Voting System Performance Guidelines 6 Telecommunications Requirements 7 8 5 7 8 6 7 8 7 Preserving Voter Privacy VVPAT Usability VVPAT Accessibility 123 149 150 151 Voting System Performance Guidelines 7 Security Requirements 7 Security Requirements 7 1 Scope This section describes essential security capabilities for a voting system encompassing the system's hardware software communications and documentation No predefined set of security standards will address and defeat all conceivable or theoretical threats The Guidelines articulate requirements to achieve acceptable levels of integrity and reliability The objectives of the security standards for voting systems are o To protect critical elements of the voting system o To establish and maintain controls to minimize errors o To protect the system from intentional manipulation fraud and malicious mischief o To identify fraudulent or erroneous changes to the voting system o To protect secrecy in the voting process The Voting System Performance Guidelines Volume I of the VVSG are intended to address a broad range of risks to the integrity of a voting system While it is not possible to identify all potential risks Volume I identifies several types of risks that must be addressed These include o Unauthorized changes to system capabilities for o o o o Defining ballot formats Casting and recording votes Calculating vote totals consistent with defined ballot formats Reporting vote totals o o o o o Alteration of voting system audit trails Changing or preventing the recording of a vote Introducing data for a vote not cast by a registered voter Changing calculated vote totals Preventing access to vote data--including individual votes and vote totals--by unauthorized individuals o Preventing access to voter identification data and data for votes cast by the voter such that an individual can determine the content of specific votes The requirements apply to the broad range of hardware software communications components and documentation that comprises a voting system These requirements apply to those components that are o Provided by the voting system manufacturer and the manufacturer's suppliers 124 Voting System Performance Guidelines 7 Security Requirements o Furnished by an external provider i e providers of personal computers and COTS operating systems where the components are capable of being used during voting system operation o Developed by a voting jurisdiction The requirements apply to all software used in any manner to support any voting-related activity regardless of the ownership of the software or the ownership and location of the hardware on which the software is installed or operated These requirements apply to software that operates on o Voting devices and vote counting devices installed at polling places under the control or authority of the voting jurisdiction o Ballot printers vote counting devices and other hardware typically installed at central or precinct locations including contractor facilities 7 1 1 Elements of Security Outside Manufacturer Control The requirements of this section apply to the capabilities of a voting system that must be provided by the manufacturer However an effective security program requires welldefined security practices by the purchasing jurisdiction and the personnel managing and operating the system These practices include o Administrative and management controls for the voting system and election management--including access controls o Internal security procedures o Adherence to and enforcement of operational procedures e g effective password management o Security of physical facilities o Organizational responsibilities and personnel screening Because implementation of these elements is not under the control of the manufacturer they are addressed in the Election Management Guidelines that describes the procedural aspects of conducting elections and managing the operation of voting systems However manufacturers must provide appropriate system capabilities to enable the implementation of management controls 7 1 2 Organization of This Section The guidelines presented in this section are organized as follows Access Control These standards address procedures and system capabilities that limit or detect access to critical system components in order to guard against loss of system integrity availability confidentiality and accountability 125 Voting System Performance Guidelines 7 Security Requirements Physical Security These standards address physical security measures and procedures that prevent disruption of the voting process at the polling place and corruption of voting data Software Security These standards address the installation of software including firmware in the voting system and the protection against malicious software It should be noted that computer-generated audit controls facilitate system security and are an integral part of software capability These audit requirements are presented in Subsection 5 4 Telecommunications and Data Transmission These standards address security for the electronic transmission of data between system components or locations over private public and wireless networks Use of Public Communications Networks These standards address security for systems that communicate individual votes or vote totals over public communications networks Wireless Communications These standards address the security of the voting system and voting data when wireless is used Independent Verification Systems This section provides an introduction to the concept of independent verification as a method to demonstrate voting system integrity This discussion provides the context for the requirements for DREs with voter verifiable paper audit trails Direct-Recording Electronic Systems with Voter Verifiable Paper Audit Trails optional This capability is not required for national certification These guidelines are provided for use by states that require this feature for DRE systems 7 2 Access Control Access controls are procedures and system capabilities that detect or limit access to system components in order to guard against loss of system integrity availability confidentiality and accountability Access controls provide reasonable assurance that system resources such as data files application programs and computer-related facilities and equipment are protected against unauthorized operation modification disclosure loss or impairment Unauthorized operations include modification of compiled or interpreted code run-time alteration of flow control logic or of data and abstraction of raw or processed voting data in any form other than a standard output report by an authorized operator Access controls may include physical controls such as keeping computers in locked rooms to limit physical access and technical controls such as security software programs designed to prevent or detect unauthorized access to sensitive files The access controls described in this section are limited to those controls required to be provided by system manufacturers 126 Voting System Performance Guidelines 7 Security Requirements 7 2 1 General Access Control General requirements address the high-level functionality of a voting system These are the fundamental access control requirements upon which other requirements in this section are based a Voting system equipment shall provide access control mechanisms designed to permit authorized access to the voting system and to prevent unauthorized access to the voting system i Access control mechanisms on the EMS shall be capable of identifying and authenticating individuals permitted to perform operations on the EMS b Voting system equipment shall provide controls that permit or deny access to the device's software and files c The default access control permissions shall implement the minimum permissions needed for each role or group identified by a device d The voting system equipment shall prevent a lower-privileged process from modifying a higher-privileged process e An administrator of voting system equipment shall authorize privileged operations f Voting system equipment shall prevent modification to or tampering with software or firmware through any means other than the documented procedure for software upgrades 7 2 2 Access Control Identification Identification requirements provide controls for accountability when operating and administering a voting system a The voting system shall identify users roles and or processes to which access is granted and the specific functions and data to which each entity holds authorized access b Voting system equipment that implement role-based access control shall support the recommendations for Core RBAC in the ANSI INCITS 359-2004 American National Standard for Information Technology- Role Based Access Control document c Voting system equipment shall allow the administrator group or role to configure the permissions and functionality for each identity group or role to include account and group role creation modification and deletion 7 2 3 Access Control Authentication Authentication establishes the validity of the identity of the user application or process interacting with the voting system Authentication is based on the identification provided by the user application or process interacting with the voting system User authentication is generally classified in one of the following three categories 127 Voting System Performance Guidelines 7 Security Requirements o Something the user knows - this is usually a password pass phrase or PIN o Something the user has - this is usually a token that may be either hardware or software based such as a smart card o Something the user is - this is usually a fingerprint retina pattern voice pattern or other biometric data Traditional password authentication is a single factor authentication method A more secure method of authentication combines the various methods of authentication into two-factor authentication or multi-factor authentication For example a user may use an authentication token and a passphrase for authentication Using multi-factor provides stronger authentication than single factor There are also cryptographic-based authentication methods such as digital signatures and challenge-response authentication which are either software or hardware-based based tokens The following authentication requirements apply to all voting system equipment a Voting system equipment shall authenticate users prior to granting them access to system functions or data b When private or secret authentication data is stored in voting system equipment the data shall be protected to ensure that the confidentiality and integrity of the data is not violated c Voting system equipment shall allow the administrator group or role to set and change passwords pass phrases and keys d Voting system equipment shall allow privilege groups or roles to be disabled and allow new individual privileged groups or roles to be created e Voting system equipment shall lock out groups roles or individuals after a specified number of consecutive failed authentication attempts within a predefined time period f Voting systems shall allow the administrator group or role to configure the account lock out policy including the time period within which failed attempts must occur the number of consecutive failed access attempts allowed before lock out and the length of time the account is locked out g If the voting system uses a user name and password authentication method the voting system shall allow the administrator to enforce password strength histories and expiration h The voting system shall allow the administrator group or role to specify password strength for all accounts including minimum password length use of capitalized letters use of numeric characters and use of non-alphanumeric characters i The voting system shall enforce password histories and allow the administrator to configure the history length j Voting system equipment shall ensure that the username is not used in the password k Voting systems shall provide a means to automatically expire passwords in accordance with the voting jurisdiction's policies 128 Voting System Performance Guidelines 7 Security Requirements 7 2 4 Access Control Authorization Authorization is the process of determining access rights based on authentication of a user application or process within a voting system Authorization permits or denies access to an object by a subject Subjects may be users applications or processes that interact with the voting system Objects may be files or programs within the voting system a Voting systems shall ensure that only authorized roles groups or individuals have access to election data b Voting systems shall explicitly authorize subject's access based on access control lists or policies c Voting systems shall explicitly deny subject's access based on access control lists or policies 7 3 Physical Security Measures A voting system's sensitivity to disruption or corruption of data depends in part on the physical location of equipment and data media Most often the disruption of voting and vote counting results from a physical violation of one or more areas of the system thought to be protected Therefore security procedures shall address physical threats and the corresponding means to defeat them a Any unauthorized physical access shall leave physical evidence that an unauthorized event has taken place b Voting systems shall only have physical ports and access points that are essential to voting operations and or to voting system testing and or auditing c An event log entry that identifies the name of the affected device shall be generated if a component connected to a piece of voting system equipment is disconnected while polls are open d Ports disabled while polls are open shall only be re-enabled by authorized administrators e Access points such as covers and panels shall be secured by locks or tamperevident seals or tamper resistant countermeasures shall be implemented so that the authorized election official can monitor access to voting system components through these points f Ballot boxes shall be designed such that any unauthorized physical access results in physical evidence that an unauthorized event has taken place 7 3 1 Polling Place Security For polling place operations manufacturers shall develop and provide detailed documentation of measures to enable poll workers to physically protect and perform orderly shutdown of voting equipment to counteract vandalism civil disobedience and similar occurrences 129 Voting System Performance Guidelines 7 Security Requirements The measures shall allow the immediate detection of tampering with vote casting devices and precinct ballot counters They also shall control physical access to a telecommunications link if such a link is used 7 3 2 Central Count Location Security a Manufacturers shall develop and document in detail the measures to be taken in a central counting environment b These measures shall include physical and procedural controls related to the handling of ballot boxes preparing of ballots for counting counting operations and reporting data 7 4 Software Security Voting systems shall meet specific security requirements for the installation of software and for protection against malicious software 7 4 1 Software and Firmware Installation The system shall meet the following requirements for installation of software including hardware with embedded firmware a If software is resident in the system as firmware the manufacturer shall require and state in the system documentation that every device is to be retested to validate each ROM prior to the start of elections operations b To prevent alteration of executable code no software shall be permanently installed or resident in the voting system unless the system documentation states that the jurisdiction must provide a secure physical and procedural environment for the storage handling preparation and transportation of the system hardware c The voting system bootstrap monitor and device-controller software may be resident permanently as firmware provided that this firmware has been shown to be inaccessible to activation or control by any means other than by the authorized initiation and execution of the vote counting program and its associated exception handlers d The election-specific programming may be installed and resident as firmware provided that such firmware is installed on a component such as a computer chip other than the component on which the operating system resides e After initiation of election day testing no source code or compilers or assemblers shall be resident or accessible 130 Voting System Performance Guidelines 7 Security Requirements 7 4 2 Protection Against Malicious Software a Voting systems shall deploy protection against the many forms of threats to which they may be exposed such as file and macro viruses worms Trojan horses and logic bombs b Manufacturers shall develop and document the procedures to be followed to ensure that such protection is maintained in a current status 7 4 3 Software Distribution and Setup Validation Subsections 7 4 4 7 4 5 and 7 4 6 specify requirements for the distribution of voting system software and the setup validation performed on voting system equipment These requirements are applicable to voting systems that have completed certification testing The goal of the software distribution requirements is to ensure that the correct voting system software has been distributed without modification The goal of setup validation requirements including requirements for verifying the presence of certified software and the absence of other software is to ensure that voting system equipment is in a proper initial state before being used In general a voting system can be considered to be composed of multiple associated systems including polling place systems central counting aggregation systems and election management systems These other systems may reside on different computer platforms at different locations and run different software Voting system software is considered to be all executable code and associated configuration files critical for the proper operation of the voting system regardless of the location of installation and functionality provided This includes third party software such as operating systems drivers and database management systems 7 4 4 Software Distribution a The manufacturer shall document all software including voting system software third party software such as operating systems and drivers to be installed on the voting system and installation programs i The documentation shall have a unique identifier such as a serial number or part number for the following set of information documentation software manufacturer name product name version the certification application number of the voting system file names and paths or other location information such as storage addresses of the software ii The documentation shall designate all software files as static semi-static or dynamic 131 Voting System Performance Guidelines 7 Security Requirements Discussion Static voting system software such as executable code does not change based on the election being conducted or the voting equipment upon which it is installed Semi-static voting system software contains configuration information for the voting system based on the voting equipment that is installed and the election being conducted Semi-static software is only modified during the installation of a the voting system software on voting equipment or b the election-specific software such as ballot formats Dynamic voting system software changes over time once installed on voting equipment However the specific time or value of the change in the dynamic software is usually unknown in advance making it impossible to create reference information to verify the software 7 4 5 Software Reference Information a The manufacturer shall provide the EAC and any repository designated by a state with a copy of the software installation disk which the manufacturer will distribute to purchasers i All voting system software installation programs and third party software such as operating systems and drivers used to install or to be installed on voting system equipment shall be distributed using write protected storage media ii The manufacturer shall document that the process used to verify the software distributed on unalterable storage media is the certified software by using the reference information provided by the EAC or other designated repository before installing the software b The voting system equipment shall be designed to allow the voting system administrator to verify that the software is the certified software by comparing it to reference information produced by the EAC or other designated repository 7 4 6 Software Setup Validation The following requirements support the security of voting systems by providing methods to verify that only certified software is present on voting systems It includes requirements for two software verification techniques One method verifies digital signatures on software prior to installation on pieces of voting system equipment This is a useful mechanism that helps prevent accidental or malicious software from being installed and could be employed by any voting system to protect against unauthorized software The second method provides an external interface to voting system software A separate piece of equipment could use this interface to verify the software on the voting system However this method merely provides a mechanism for detecting unauthorized software and by itself does not help prevent the installation of accidental or malicious software a Setup validation methods shall verify that only certified software is present on the voting equipment Certified software is COTS software components needed 132 Voting System Performance Guidelines 7 Security Requirements to run the voting system and voting software components identified by the manufacturer as authorized b The manufacturer shall provide a method to comprehensively list all software files that are installed on voting systems i This method shall list version names and numbers for all application software on the voting system ii This method should list of the date of installation for all application software on the voting system c Setup validation methods shall include a software verification method that ensures that the voting system software has not been modified illegitimately i The voting systems shall include any supporting software and hardware necessary to conduct the software verification method ii The manufacturer shall document the process used to conduct the software verification method iii The software verification method shall not modify the voting system software on the voting system d Voting systems shall include a software verification method that either verifies software prior to installation or a method that verifies software using an external interface Voting systems may include both software verification methods Voting systems may provide ancillary setup validation methods including methods for verifying or identifying installed software other than those described in this section There are no specific requirements for ancillary setup validation methods However any method intended to serve as the voting system software verification method must meet the requirements outlined in this section e Voting systems which implement a software verification method that verifies software prior to installation shall meet the following requirements i The voting system shall contain no more than one method for installing updating or removing software on a system o Voting system equipment shall prevent processes from installing software except for the one specific software installation process identified by the manufacturer o The voting system manufacturer shall document the procedures for installing updating and removing voting system software configuration files and data files o Voting system equipment shall prevent processes from installing updating or removing software while the polls are open o Voting system equipment shall prevent the execution of software not installed using the specified software installation process ii The voting system shall only allow authenticated administrators to install software on voting equipment The voting system shall present the administrator with a description of the software change being performed including o A list of all applications and or file names being updated o The type of action performed on each application and or file e g new application file deletion or overwriting of existing file iii Voting system equipment shall store the current version identification of all software installed on the voting system equipment o The current version identification shall be included as part of reports created by the voting system equipment 133 Voting System Performance Guidelines 7 Security Requirements o The current version identification shall be displayed as part of the voting system equipment start up process iv The process for installing updating and removing software shall make software changes based on information contained in software update packages Software update packages shall minimally contain the following information o A unique identifier for the software update package o Names of the applications or files modified during the update process o Version numbers of the applications or files modified during the update process o Any software prerequisites or dependencies for the software involved in the update o A description of the type of action performed on each application and or file e g new application file deletion or overwriting of existing file o The binary data of any new or updated files involved in the update process v Software update packages shall be digitally signed by using a NIST approved algorithm with a security strength of at least 112 bits vi The software installation process shall verify digital signatures software version identification software prerequisites and dependencies and manufacturer specific authorization information associated with the software before the software is installed The software installation process shall not install software with invalid digital signatures version numbers or manufacturer specific authorization information and shall not install software on systems that do not meet the update requisites vii The voting system shall have the capability to prevent the installation of previous versions of applications or files viii The software installation process shall result in information being stored in the voting system equipment's log such that altering or deleting log entries or the log will be detected ix The minimum information to be included in the voting system audit log shall be o Success or failure of the software installation process o Cause of a failed software installation such as invalid version identification digital signature etc o Application or file name s and version number s o A description of the type of action performed on each application and or file e g new application file deletion or overwriting of existing file o A cryptographic hash of the software update package using FIPS 1402 level 1 or higher validated cryptographic module f If software is verified after being installed on the voting system equipment the voting system equipment shall provide an external interface to the location of the voting system software for software verification purposes i The external interface o Shall be protected using tamper evident techniques o Shall have a physical or logical indicator showing when the interface is enabled and disabled 134 Voting System Performance Guidelines 7 Security Requirements o Shall be disabled or protected during voting o Should provide a direct read-only access to the location of the voting system software without the use of installed software ii The verification process should be able to be performed using COTS software and hardware available from sources other than the voting system manufacturer o If the process uses hashes or digital signatures then the verification software shall use a FIPS 140-2 level 1 or higher validated cryptographic module o The verification process shall either a use reference information on unalterable storage media received from the repository or b verify the digital signature of the reference information on any other media g Setup validation methods shall verify the contents of all system storage locations e g system registers variables files etc containing election specific information e g ballot style candidate registers measure registers etc i The manufacturer should provide a method to query the voting system to determine the value contained in all system storage locations containing election specific information ii The manufacturer shall document the default values of all system storage locations that hold election specific information 7 5 Telecommunications and Data Transmission There are four areas that must be addressed by telecommunications and data transmission security capabilities access control data integrity detection and prevention of data interception and protection against external threats 7 5 1 Maintaining Data Integrity Voting systems that use telecommunications to communicate between system components and locations are subject to the same security requirements governing access to any other system hardware software and data function a Voting systems that use electrical or optical transmission of data shall ensure the receipt of valid vote records is verified at the receiving station This should include standard transmission error detection and correction methods such as checksums or message digest hashes Verification of correct transmission shall occur at the voting system application level and ensure that the correct data is recorded on all relevant components consolidated within the polling place prior to the voter completing casting of his or her ballot i Cryptography used to verify the receipt of vote records shall use NIST approved algorithms with security strength of at least 112 bits Message Authentication Code MAC keys shall have a security strength of at least 112 bits 135 Voting System Performance Guidelines 7 Security Requirements b Voting systems that use telecommunications to communicate between system components and locations shall i Implement encryption using NIST approved algorithms with a security strength of at least 112 bits within a FIPS 140-2 level 1 or higher validated cryptographic module operating in FIPS mode ii Provide a means to detect the presence of an intrusive process such as an Intrusion Detection System 7 5 2 Protection Against External Threats a Voting systems that use public telecommunications networks shall implement protections against external threats to which commercial products used in the system may be susceptible b Voting systems that use public telecommunications networks shall provide system documentation that clearly identifies all COTS hardware and software products and communications services used in the development and or operation of the voting system including operating systems communications routers modem drivers and dial-up networking software i Such documentation shall identify the name manufacturer and version used for each such component c Voting systems that use public telecommunications networks shall use protective software at the receiving-end of all communications paths to i Detect the presence of a threat in a transmission ii Remove the threat from infected files data iii Prevent against storage of the threat anywhere on the receiving device iv Provide the capability to confirm that no threats are stored in system memory and in connected storage media v Provide data to the system audit log indicating the detection of a threat and the processing performed d Manufacturers shall use multiple forms of protective software as needed to provide capabilities for the full range of products used by the voting system 7 5 3 Monitoring and Responding to External Threats Voting systems that use public telecommunications networks may become vulnerable by virtue of their system components to external threats to the accuracy and integrity of vote recording vote counting and vote consolidation and reporting processes Therefore manufacturers of such systems shall document how they plan to monitor and respond to known threats to which their voting systems are vulnerable This documentation shall provide a detailed description including scheduling information of the procedures the manufacturer will use to a Monitor threats such as through the review of assessments advisories and alerts for COTS components issued by the Computer Emergency Response Team CERT for which a current listing can be found at http www cert org 136 Voting System Performance Guidelines 7 Security Requirements b Evaluate the threats and if any proposed responses c Develop responsive updates to the system and or corrective procedures d Submit the proposed response to the VSTLs and appropriate states for approval identifying the exact changes and whether or not they are temporary or permanent e After implementation of the proposed response is approved assist clients either directly or through detailed written procedures how to update their systems and or to implement the corrective procedures within the timeframe established f Address threats emerging too late to correct the system by i Providing prompt emergency notification to the EAC VSTLs and the affected states and user jurisdictions ii Assisting client jurisdictions directly or advising them through detailed written procedures to disable the public telecommunications mode of the system iii Modifying the system after the election to address the threat submitting the modified system to a VSTL and the EAC for approval and assisting client jurisdictions directly or advising them through detailed written procedures to update their systems and or to implement the corrective procedures after approval 7 5 4 Shared Operating Environment Ballot recording and vote counting can be performed in either a dedicated or nondedicated environment If ballot recording and vote counting operations are performed in an environment that is shared with other data processing functions both hardware and software features shall be present to protect the integrity of vote counting and of vote data Systems that use a shared operating environment shall a Use security procedures and logging records to control access to system functions b Partition or compartmentalize voting system functions from other concurrent functions at least logically and preferably physically as well c Control system access by means of passwords and restrict account access to necessary functions only d Have capabilities in place to control the flow of information precluding data leakage through shared system resources 7 5 5 Election Returns If the voting system provides access to election returns or interactive inquiries the system shall a Allow authorized administrators the ability to disable or restrict access to election returns for equipment that operates in a central counting environment 137 Voting System Performance Guidelines 7 Security Requirements This requirement applies as well to polling place equipment that contains a removable memory module or that may be removed in its entirety to a central place for the consolidation of polling place returns b Design voting system software and its security environment such that data accessible to interactive queries resides in an external file or database created and maintained by the elections software under the restrictions applying to any other output report i The output file or database has no provision for write access back to the system ii Persons whose only authorized access is to the file or database are denied write access both to the file or database and to the system 7 6 Use of Public Communications Networks Voting systems that transmit data over public telecommunications networks face security risks that are not present in other voting systems This section describes requirements applicable to voting systems that use public telecommunications networks 7 6 1 Data Transmission a All systems that transmit data over public telecommunications networks shall i Preserve the secrecy of voter ballot selections and prevent anyone from violating ballot privacy ii Employ digital signatures for all communications between the vote server and other devices that communicate with the server over the network iii Require that at least two authorized election officials activate any critical operation regarding the processing of ballots transmitted over a public communications network i e the passwords or cryptographic keys of at least two authorized election officials are required to perform processing of votes b Cryptography used to provide protection of data transmitted over public telecommunications networks shall use NIST approved algorithms with security strength of at least 112 bits c Message Authentication Code MAC keys shall have a security strength of at least 112 bits The security strengths of cryptographic algorithms can be found in NIST Special Publication 800-57 Recommendation for Key Management - Part 1 General 7 6 2 Casting Individual Ballots Systems designed for transmission of data over public networks shall meet security standards that address the security risks attendant with the casting of ballots from polling places controlled by election officials using voting devices configured and installed by election officials and or their manufacturer or contractor and using in-person authentication of individual voters 138 Voting System Performance Guidelines 7 Security Requirements 7 6 2 1 Documentation of Mandatory Security Activities Manufacturers of voting systems that cast individual ballots over a public telecommunications network shall provide detailed descriptions of a All activities mandatory to ensuring effective voting system security to be performed in setting up the system for operation including testing of security before an election b All activities that should be prohibited during voting equipment setup and during the timeframe for voting operations including both the hours when polls are open and when polls are closed 7 6 2 2 Ability to Operate During Interruption of Service These systems shall provide the following capabilities to provide resistance to interruptions of telecommunications service that prevent voting devices at the polling place from communicating with external components via telecommunications a Detect the occurrence of a telecommunications interruption at the polling place and switch to an alternative mode of operation that is not dependent on the connection between polling place voting devices and external system components b Provide an alternate mode of operation that includes the functionality of a conventional electronic voting system without losing any votes c Create and preserve an audit trail of every vote cast during the period of interrupted communication and system operation in conventional electronic voting system mode d Upon reestablishment of communications transmit and process votes accumulated while operating in conventional electronic voting system mode with all security safeguards in effect e Ensure that all safeguards related to voter identification and authentication are not affected by the procedures employed by the system to counteract potential interruptions of telecommunications capabilities 7 7 Wireless Communications This section provides requirements for implementing and using wireless communications within a voting system These requirements reduce but do not eliminate the risk of using wireless communications for voting systems Wireless is defined as any means of communications that occurs without wires This normally covers the entire electromagnetic spectrum For the purposes of this section wireless includes radio frequency infrared and microwave This section provides requirements and considerations that apply to external wireless communications capabilities existing on voting equipment or as a component within a voting system 139 Voting System Performance Guidelines 7 Security Requirements These requirements may be applied to internal wireless communications but this is not required when the physical container that houses the voting equipment or voting system is considered adequate to protect the internal wireless between or among voting system components Since the wireless communications path on which the signals travel is via the air and not a wire or cable devices other than those intended to receive the wireless signal e g voting data can receive intentionally and unintentionally the wireless signals Some of the wireless communications paths i e signals are weakened by walls and distance but are not stopped This makes it possible to eavesdrop from a distance as well as transmit wireless signals e g interference or intrusive data from a distance In many cases the wireless signals cannot be seen heard or felt thus making the presence of wireless communication hard to determine by the human senses The requirements in this section mitigate the risks associated with wireless by controlling and identifying usage and protecting the transmitted data and path There are other concerns when evaluating wireless usage specifically radio frequency RF A device's radio frequencies usage and the power output are governed by Federal Communications Commission FCC regulations and therefore all RF wireless communications devices are subject to the applicable FCC requirements However these FCC regulations do not fully address RF wireless interference caused by multiple FCC compliant devices That is the RF wireless used in a voting system may be using the same radio frequency as another non-voting wireless system and which may potentially cause a degradation of the wireless performance or a complete wireless failure for the voting system Sometimes a particular wireless technology permits a power output range which may be used to overcome interference received from another device A radio emissions site test can determine the extent of potential existing interference at the location where the wireless voting system is to be used A radio emission site test can also determine the extent that the RF wireless transmission of the voting system escapes the building in which the RF wireless voting system is used 7 7 1 Controlling Usage a If wireless communications are used in a voting system then the manufacturer shall supply documentation describing how to use all aspects of wireless communications in a secure manner This documentation shall include i A complete description of the uses of wireless in the voting system including descriptions of the data elements and signals that are to be carried by the wireless mechanism ii A complete description of the vulnerabilities associated with this proposed use of wireless including vulnerabilities deriving from the insertion deletion modification capture or suppression of wireless messages iii A complete description of the techniques used to mitigate the risks associated with the described vulnerabilities including techniques used by the manufacturer to ensure that wireless cannot send or receive messages 140 Voting System Performance Guidelines 7 Security Requirements other than those situations specified in the documentation Cryptographic techniques shall be carefully and fully described including a description of cryptographic key generation management use certification and destruction iv A rationale for the inclusion of wireless in the proposed voting system based on a careful and complete description of the perceived advantages and disadvantages of using wireless for the documented uses compared to using non-wireless approaches Discussion In general convenience is not a sufficiently compelling reason on its own to justify the inclusion of wireless communications in a voting system Convenience must be balanced against the difficulty of working with cryptographic keys b The details of all cryptographic protocols used for wireless communications including the specific features and data shall be documented c The wireless documentation shall be closely reviewed for accuracy completeness and correctness d There shall be no undocumented use of the wireless capability nor any use of the wireless capability that is not entirely controlled by an election official Discussion This can be tested by reviewing all of the software hardware and documentation and by testing the status of wireless activity during all phases of testing e If a voting system includes wireless capabilities then the voting system shall be able to accomplish the same function if wireless capabilities are not available due to an error or no service i The manufacturer shall provide documentation how to accomplish these functions when wireless is not available f The system shall be designed and configured so it is not vulnerable to a single point of failure using wireless communications that causes a total loss of any voting capabilities g If a voting system includes wireless capabilities then the system shall have the ability to turn on the wireless capability when it is to be used and to turn off the wireless capability when the wireless capability is not in use h If a voting system includes wireless capabilities then the system shall not activate the wireless capabilities without confirmation from an elections official 7 7 2 Identifying Usage Since there are a wide variety of wireless technologies both standard and proprietary and differing physical properties of wireless signals it is important to identify some of the characteristics of the wireless technologies used in the voting system 141 Voting System Performance Guidelines 7 Security Requirements a If a voting system provides wireless communications capabilities then there shall be a method for determining the existence of the wireless communications capabilities b If a voting system provides wireless communications capabilities then there shall be an indication that allows one to determine when the wireless communications such as radio frequencies capability is active c The indication shall be visual d If a voting system provides wireless communications capabilities then the type of wireless communications used such as radio frequencies shall be identified either via a label or via the voting system documentation 7 7 3 Protecting Transmitted Data The transmitted data especially via wireless communications needs to be protected to ensure confidentiality and integrity Examples of election information that needs to be protected include ballot definitions voting device counts precinct counts opening of poll signal and closing of poll signal Examples of other information that needs to be protected include protocol messages address or device identification information and passwords Since radio frequency wireless signals radiate in all directions and pass through most construction material anyone may easily receive the wireless signals In contrast infrared signals are line of sight and do not pass through most construction material However infrared signals can still be received by other devices that are in the line of sight Similarly wireless signals can be transmitted by others to create unwanted signals Thus encryption is required to protect the privacy and confidentiality of the voting information a All information transmitted via wireless communications shall be encrypted and authenticated--with the exception of wireless T-coil coupling--to protect against eavesdropping and data manipulation including modification insertion and deletion i Cryptography used for encryption and authentication shall use NIST approved algorithms with security strength of at least 112 bits Message Authentication Code MAC keys shall have a security strength of at least 112 bits ii The cryptographic modules used shall comply with FIPS 140-2 Security Requirements for Cryptographic Modules b The capability to transmit non-encrypted and non-authenticated information via wireless communications shall not exist c If audible wireless communication is used and the receiver of the wireless transmission is the human ear then the information shall not be encrypted Discussion 7 7 3 c specifically covers wireless T-Coil coupling for assistive devices used by people who are hard of hearing 142 Voting System Performance Guidelines 7 Security Requirements 7 7 4 Protecting the Wireless Path If wireless communications are used then the following capabilities shall exist in order to mitigate the effects of a denial of service DoS attack a The voting system shall be able to function properly throughout a DoS attack since the DoS attack may continue throughout the voting period b The voting system shall function properly as if the wireless capability were never available for use c Alternative procedures or capabilities shall exist to accomplish the same functions that the wireless communications capability would have done d If infrared is being used the shielding shall be strong enough to prevent escape of the voting system signal as well as strong enough to prevent infrared saturation jamming Discussion Since infrared has the line-of-sight property securing the wireless path can be accomplished by shielding the path between the communicating devices with an opaque enclosure However this is only practical for short distances This shielding would also help prevent accidental eye damage from the infrared signal 7 7 5 Protecting the Voting System Physical security measures to prevent access to a voting system are not possible when using a wireless communications interface because there is no discrete physical communications path that can be secured a The security requirements in Subsection 2 1 1 shall be applicable to systems with wireless communications b The accuracy requirements in Subsection 2 1 2 shall be applicable to systems with wireless communications c The use of wireless communications that may cause impact to the system accuracy through electromagnetic stresses is prohibited d The error recovery requirements in Subsection 2 1 3 shall be applicable to systems with wireless communications e All wireless communications actions shall be logged i The log shall contain at least the following entries times when the wireless is activated and deactivated services accessed identification of device to which data was transmitted to or received from identification of authorized user and successful and unsuccessful attempts to access wireless communications or service Discussion Other information such as the number of frames or packets transmitted or received at various logical layers may be useful but is dependent on the wireless technology used 143 Voting System Performance Guidelines 7 Security Requirements f Device authentication shall occur before any access to or services from the voting system are granted through wireless communications Discussion Authentication is an important element to protect the security of wireless communications Authentication verifies the identity and legitimacy of users devices and services i User authentication shall be at least level 2 as per NIST Special Publication 800-63-2 Version Electronic Authentication Guideline 7 8 Voter Verifiable Paper Audit Trail Requirements This section contains requirements for DREs with a Voter Verifiable Paper Audit Trail VVPAT component henceforth referred to as VVPAT voting systems A VVPAT voting system shall consist minimally of the following fundamental components o A voting device on which a voter makes selections and prepares to cast a ballot o A printer that prints a paper record summary of the voter's ballot selections and that allows the voter to compare it with the electronic ballot selections o A mechanism by which the voter may indicate acceptance or rejection of the paper record o Ballot box cartridge to contain accepted and voided paper records and o A paper record for each electronic ballot image The paper record may be printed on a separate sheet for each record cut-sheet VVPAT or on a continuous paper roll paper-roll VVPAT VVPAT capability is not required for national certification However these requirements will be applied for certification testing of DRE systems that are intended for use in states that require DREs to provide this capability The manufacturer's certification testing application to the EAC must indicate whether the system being presented for testing includes this capability as provided under Subsection 1 5 1 4 extensions 7 8 1 Display and Print a Paper Record a VVPAT voting systems shall provide capabilities for the voter to review a paper record of ballot selections and a summary of the voter's electronic ballot selections prior to casting a ballot b VVPAT voting systems shall create a paper record that election officials can use to reconstruct the full set of totals from the election c Each paper record shall contain a human-readable summary of the electronic ballot image record In addition all paper records shall contain audit-related information including i Machine ID ii Reporting context such as precinct or election district iii Ballot style 144 Voting System Performance Guidelines 7 Security Requirements iv Date of election or date record printed and v Complete summary of voter's choices 7 8 2 Approve or Void the Paper Record a When a voter indicates that the paper record is to be accepted the VVPAT voting system shall i Immediately print an indication that the vote has been accepted in view of the voter ii Electronically store the electronic ballot image record as a cast vote and iii Deposit the paper record into a secure receptacle b When a voter indicates that the paper record is to be rejected the VVPAT voting system shall i Immediately print an unambiguous indication that the vote has been rejected in view of the voter ii Electronically store a record that the paper record was rejected and iii Deposit the rejected paper record into the secure receptacle c The VVPAT voting system shall have the capacity to be configured to limit the number of times a single voter may reject a paper record without election official intervention The VVPAT voting system shall support limits between zero any rejected paper record requires election official intervention to five times and may support an unlimited number of rejections without election official intervention d The VVPAT voting system shall have the capacity to limit the total number of paper records that a machine may reject before election official intervention is required The VVPAT voting system shall have a default limit of three rejected paper records before election official intervention is required The VVPAT voting system shall permit the setting of no limit so that no number of total rejected paper records requires immediate election official intervention e The VVPAT voting system shall have the capacity to be configured to remove any indication of the voter's choices from the screen when the configured limit of rejected paper records per voter or per machine is reached f When a VVPAT voting system reaches a configured limit of rejected paper records per voter or per machine it shall do the following i Place the paper record that has been rejected into the ballot box or other receptacle ii Clearly display that a paper record has been rejected and indicate the need for election official intervention and iii Suspend normal operations until re-enabled by an authorized election official 7 8 3 Electronic and Paper Record Structure a Electronic ballot images shall be recorded in a randomized order by the voting system for the election NIST Special Publication 800-90 Recommendation for 145 Voting System Performance Guidelines 7 Security Requirements Random Number Generation Using Deterministic Random Bit Generators specifies techniques for the generation of random numbers that can be used to randomize the order of ballot images in a cryptographically sound way For each voted ballot this includes i Ballot style and reporting context such as precinct or election district ii For each contest o The choice recorded including undervotes and write-ins and o Any information collected by the vote-capture device electronically about each write-in iii Information specifying whether the ballot is provisional early voting or election day voting Types of provisional ballots such as regular provisional extended hours provisional and regular extended hours are jurisdiction-dependent iv Information linking the electronic ballot image to a paper record if such functionality is enabled in the voting system b The voting system shall provide the capability to export the collection of electronic ballot images in a publicly documented format such as XML or include a utility to export the records into a publicly documented format for offline viewing c Electronic ballot images shall be digitally signed by the voting system The digital signature shall be generated using a NIST-approved digital signature algorithm with a security strength of at least 112 bits implemented within a FIPS 140-2 validated cryptographic module operating in FIPS mode d The human-readable contents of the paper record should be created in a manner that is machine-readable by optical character recognition e Paper-roll VVPAT voting systems shall mark paper rolls with the following i Machine ID ii Reporting context such as precinct or election district iii Date of election or date record printed iv If multiple paper rolls were produced during this election on this device the number of the paper roll e g Roll #2 and f Paper-roll VVPAT voting systems shall include the following on each paper record i Ballot style ii Type of voting e g provisional early etc iii Complete summary of voter's choices iv For each ballot contest o Contest name e g Governor o Any additional information needed for unambiguous interpretation of the paper record o An indication if the contest was undervoted and o An indication if the choice is a write-in vote v An indication of whether the paper record has been accepted or rejected by the voter g Paper-roll VVPAT voting systems shall not split paper records across rolls each paper record must be contained in its entirety by the paper roll h Cut-sheet VVPAT voting systems shall include the following on each paper record i Machine ID 146 Voting System Performance Guidelines 7 Security Requirements ii iii iv v vi vii Reporting context such as precinct or election district Date of election or date record printed Ballot style Type of voting e g provisional early etc Complete summary of voter's choices For each ballot contest o Contest name e g Governor o Any additional information needed for unambiguous interpretation of the paper record o An indication if the contest was undervoted and o An indication if the choice is a write-in vote viii An indication of whether each sheet has been accepted or rejected by the voter i If a cut-sheet VVPAT voting system splits paper records across multiple sheets of paper each sheet shall include i Page number of this sheet and total number of sheets e g page 1 of 4 ii Ballot style iii Reporting context such as precinct or election district iv An indication that the sheet's contents have been accepted or rejected by the voter and v Any correspondence information included to link the paper record to its corresponding electronic ballot image record j If a cut-sheet VVPAT voting system splits paper record across multiple sheets of paper it shall not split ballot contests across sheets k If a cut-sheet VVPAT voting system splits paper records across multiple sheets of paper the ballot choices on each sheet shall be submitted to the voter for verification separately according to the following i The voter shall be presented a verification screen for the contents of each sheet separately at the same time as the voter is able to verify the contents of the part of the paper record on the sheet ii When a voter accepts or rejects the contents of a sheet the votes contained on that sheet and verification screen shall be committed to memory regardless of the verification of any other sheet by the same voter iii Configurable limits on rejected paper records per voter shall count each rejected sheet as a rejected paper record iv Configurable limits on rejected paper records per machine shall not count more than one rejected paper record per voter and v When a rejected paper record requires election official intervention the VVPAT voting system shall indicate which sheets have been accepted and which rejected l The VVPAT voting system shall provide a capability to print information on each paper record sufficient for auditors to identify from an electronic ballot image record its corresponding paper record and from a paper records its corresponding electronic ballot image This capability shall be possible for election officials to enable or disable m Any information on the paper record that identifies the corresponding electronic ballot image should not be practical for the voter to read or copy by hand 147 Voting System Performance Guidelines 7 Security Requirements n The VVPAT voting system manufacturer shall include a capability for auditors to verify the correspondence between the electronic ballot image and paper record pairs if the correspondence information is printed on the paper record 7 8 4 Equipment Security and Reliability a The VVPAT printer shall be physically connected via a standard publicly documented printer port using a standard communications protocol b Tamper-evident seals or physical security measures shall protect the connection between the printer and the voting machine c If the connection between the voting machine and the printer has been broken the voting machine shall detect this event and record it in the system event log d The VVPAT voting system shall detect printer errors that may prevent paper records from being correctly displayed printed or stored such as lack of consumables such as paper ink or toner paper jams misfeeds and memory errors e If a printer error or malfunction is detected the VVPAT voting system shall i Present a clear indication to the voter and election officials of the malfunction This must indicate clearly whether the current voter's vote has been cast discarded or is waiting to be completed ii Suspend voting operations until the problem is resolved iii Allow canceling of the current voter's electronic ballot image by election officials in the case of an unrecoverable error and iv Protect the privacy of the voter while the error is being resolved f Procedures for recovery from printer errors on paper-roll VVPAT voting systems shall not expose the contents of previously cast paper records g Paper-roll VVPAT voting systems shall be designed so that when the rolls are removed from the voting device according to the following i All paper records are contained inside the secure container ii The container supports being tamper-sealed and locked and iii The container supports being labeled with the device serial number precinct and other identifying information to support audits and recounts h If a continuous paper spool is used to store paper records the manufacturer shall provide a mechanism for an auditor to unspool the paper view each paper record in its entirety and then respool the paper without modifying the paper in any way i The printer shall not be permitted to communicate with any system or machine other than the voting machine to which it is connected j The printer shall only be able to function as a printer it shall not contain any other services e g provide copier or fax functions or network capability k Protective coverings intended to be transparent on voting equipment shall be maintainable via a predefined cleaning process If the coverings become damaged such that they obscure the paper record they shall be replaceable l The paper record shall be of sufficient durability to remain unchanged for minimally 22 months to be used for verifications reconciliations and recounts conducted manually or by automated processing 148 Voting System Performance Guidelines 7 Security Requirements 7 8 5 Preserving Voter Privacy VVPAT records can be printed and stored by two different methods o Printed and stored on a continuous spool-to-spool paper roll where the voter views the paper record in a window o Printed on separate pieces of paper which are deposited in a secure receptacle If a requirement applies to only one method that will be specified Otherwise the requirement applies to both a Voter privacy shall be preserved during the process of recording verifying and auditing his or her ballot selections Discussion The privacy requirements from Section 3 also apply to voting equipment with VVPAT b When a VVPAT with a spool-to-spool continuous paper record is used a means shall be provided to preserve the secrecy of the paper record of voter selections c When a VVPAT with a spool-to-spool continuous paper record is used no record shall be maintained of which voters used which voting machine or the order in which they voted d The electronic and paper records shall be created and stored in ways that preserve the privacy of the voter Discussion For VVPAT systems that use separate pieces of paper for the record this can be accomplished in various ways including shuffling the order of the records or other methods to separate the order of stored records e The privacy of voters whose paper records contain an alternative language shall be maintained f Unique identifiers shall not be displayed in a way that is easily memorable by the voter Discussion Unique identifiers on the paper record are displayed or formatted in such a way that they are not memorable to voters such as by obscuring them in other characters g Both paper rolls and paper record secure receptacles shall be controlled protected and preserved with the same security as a ballot box 149 Voting System Performance Guidelines 7 Security Requirements 7 8 6 VVPAT Usability a All usability requirements from Subsection 3 1 shall apply to voting machines with VVPAT Discussion The requirements in this section are in addition to those in Subsection 3 1 b The voting equipment shall be capable of showing the information on the paper in a font size of at least 3 0 mm and should be capable of showing the information in at least two font ranges 3 0-4 0 mm and 6 3-9 0 mm under control of the voter or poll worker Discussion In keeping with requirements in Subsection 3 1 the paper record should use the same font sizes as displayed by the voting machine but at least be capable of 3 0 mm While larger font sizes may assist voters with poor vision certain disabilities such as tunnel vision are best addressed by smaller font sizes c The voting equipment shall display print and store the paper record in any of the written alternative languages chosen for the ballot i To assist with manual auditing candidate names on the paper record shall be presented in the same language as used on the DRE summary screen ii Information on the paper record not needed by the voter to perform verification shall be in English Discussion In addition to the voter ballot selections the marking of the paper record as accepted or void and the indication of the ballot page number need to be printed in the alternative language Other information such as precinct and election identifiers shall be in English to facilitate use of the paper record for auditing d The paper and electronic records shall be presented to allow the voter to read and compare the records without the voter having to shift his or her position e If the paper record cannot be displayed in its entirety on a single page a means shall be provided to allow the voter to view the entire record Discussion Possible solutions include scrolling the paper or printing a new sheet of paper The voter should be notified if it is not possible to scroll in reverse so they will know to complete verification in one pass f If the paper record cannot be displayed in its entirety on a single page each page of the record shall be numbered and shall include the total count of pages for the record 150 Voting System Performance Guidelines 7 Security Requirements Discussion Possible numbering schemes include Page X of Y g The instructions for performing the verification process shall be made available to the voter in a location on the voting machine Discussion All instructions must meet the usability requirements contained in Subsection 3 1 7 8 7 VVPAT Accessibility a All accessibility requirements from Subsection 3 3 shall apply to voting machines with VVPAT b If the normal voting procedure includes VVPAT the accessible voting equipment should provide features that enable voters who are visually impaired and voters with an unwritten language to perform this verification If state statute designates the paper record produced by the VVPAT to be the official ballot or the determinative record on a recount the accessible voting equipment shall provide features that enable visually impaired voters and voters with an unwritten language to review the paper record Discussion For example the accessible voting equipment might provide an automated reader that converts the paper record contents into audio output Subsection 3 3 1 e also applies 151 8 Quality Assurance and Configuration Management Table of Contents 8 8 1 8 2 Quality Assurance and Configuration Management Standards based framework for Quality Assurance and Configuration Management Configuration Management Requirements 152 153 153 154 Voting System Performance Guidelines 8 Quality Assurance and Configuration Management 8 Quality Assurance and Configuration Management The quality assurance and configuration management requirements discussed in this section help assure that voting systems conform to the requirements of the VVSG Quality Assurance is a manufacturer function with associated practices that is initiated prior to system development and continues throughout the maintenance life cycle of the voting system Quality Assurance focuses on building quality into a system and reducing dependence on system tests at the end of the life cycle to detect deficiencies thus helping ensure that the system o Meets stated requirements and objectives o Adheres to established standards and conventions o Functions consistent with related components and meets dependencies for use within the jurisdiction and o Reflects all changes approved during its initial development internal testing qualification and if applicable additional certification processes Configuration management is a set of activities and associated practices that ensures full knowledge and control of the components of a system starting with its initial development progressing through its ongoing maintenance and enhancement and including its operational life cycle 8 1 Standards based framework for Quality Assurance and Configuration Management The requirement in this section establishes the quality assurance and configuration standards for voting system to which manufacturers must conform The requirement to develop a Quality and Configuration Management manual and the detailed requirements on that manual are contained in Volume II Section 2 1 a Voting system manufacturers shall implement a quality assurance and configuration management program that is conformant with the recognized ISO standards in these areas i ISO 9000 2005 ii ISO 9001 2000 and iii ISO 10007 2003 153 Voting System Performance Guidelines 8 Quality Assurance and Configuration Management 8 2 Configuration Management Requirements This section specifies the key configuration management requirements for voting system manufacturers The requirements include those of equipment tags and configuration logs Continuation of the program in the form of usage logs is the responsibility of State and local officials a Each voting system shall have an identification tag that is attached to the voting system component The tag shall be tamper-resistant and difficult to remove The tag shall contain the following information i The voting system model identification in the form of a model number and possibly a model name The model identification identifies the exact variant or version of the system ii The serial number that uniquely identifies the system iii Identification of the manufacturer including address and contact information for technical service and iv Date of manufacture of the voting system v The system's power requirements if applicable b For each voting system manufactured a Voting System Configuration Log shall be established The Log is initialized by the configuration data supplied by the manufacturer From that point on it functions like a diary of the system Entries are made by election officials whenever any change occurs Every exception disruption anomaly and every failure is recorded Every time the cover is opened for inspection or a repair or maintenance is performed an entry details what was done and what component was changed against what other component as well as any diagnosis of failures or exceptions The Log shall be kept on a medium that allows the writing but not the modification or deletion of records The Log shall contain the following information i The information on the system tag described in Requirement a ii The identification of all critical parts components and assemblies of the system and iii The complete historical record as developed by the manufacturer per Requirement II 2 1 l of all critical parts components and assemblies included in the voting system The list of critical parts components and assemblies should be consistent with the rules for determining which of these entities is critical as specified in the Quality and Configuration Manual See Requirement Vol II 2 1 f 154 Appendix A Glossary Table of Contents Appendix A 2 A 1 Glossary 2 A 2 Sources 1 A l Voting System Performance Guidelines Appendix A Appendix A Glossary This glossary contains terms needed to understand voting systems and related areas such as security human factors and testing Sources consulted in preparing the definitions are listed in section A 2 A 1 Glossary A absentee ballot Ballot cast by a voter unable to vote in person at his or her polling place on Election Day acceptance testing Examination of a voting system and its components by the purchasing election authority usually in a simulated-use environment to validate performance of delivered units in accordance with procurement requirements and to validate that the delivered system is in fact the certified system purchased Access Board Independent federal agency whose primary mission is accessibility for people with disabilities and a leading source of information on accessible design accessibility Measurable characteristics that indicate the degree to which a system is available to and usable by individuals with disabilities The most common disabilities include those associated with vision hearing and mobility as well as cognitive disabilities Accessible Voting Station Acc-VS Voting station specially equipped for individuals with disabilities referred to in HAVA 301 a 3 B accreditation Formal recognition that a laboratory is competent to carry out specific tests or calibrations accreditation body 1 Authoritative body that performs accreditation 2 An independent organization responsible for assessing the performance of other organizations against a recognized standard and for formally confirming the status of those that meet the standard accuracy 1 Extent to which a given measurement agrees with an accepted standard for that measurement 2 Closeness of the agreement between the result of a measurement and a true value of the particular quantity subject to measurement Accuracy is a qualitative concept and is not interchangeable with precision A-2 Voting System Performance Guidelines Appendix A accuracy for voting systems Ability of the system to capture record store consolidate and report the specific selections and absence of selections made by the voter for each ballot position without error Required accuracy is defined in terms of an error rate that for testing purposes represents the maximum number of errors allowed while processing a specified volume of data alert time The amount of time the system will wait for detectible voter activity after issuing an alert before going into an inactive state requiring poll worker intervention alternative format The ballot or accompanying information is said to be in an alternative format if it is in a representation other than the standard ballot language and format Examples include but are not limited to languages other than English Braille ASCII text large print recorded audio application logic Software firmware or hardwired logic from any source that is specific to the voting system with the exception of border logic audio ballot a ballot in which a set of offices is presented to the voter in spoken rather than written form audio-tactile interface ATI Voter interface designed to not require visual reading of a ballot Audio is used to convey information to the voter and sensitive tactile controls allow the voter to convey information to the voting system audit Systematic independent documented process for obtaining records statements of fact or other relevant information and assessing them objectively to determine the extent to which specified requirements are fulfilled audit trail Recorded information that allows election officials to review the activities that occurred on the voting equipment to verify or reconstruct the steps followed without compromising the ballot or voter secrecy availability The percentage of time during which a system is operating properly and available for use B ballot The official presentation of all of the contests to be decided in a particular election See also audio ballot ballot image video ballot electronic ballot interface ballot configuration Particular set of contests to appear on the ballot for a particular election district their order the list of ballot positions for each contest and the binding of candidate names to ballot positions ballot counter Process in a voting device that counts the votes cast in an election A-3 Voting System Performance Guidelines Appendix A ballot counting logic The software logic that defines the combinations of voter choices that are valid and invalid on a given ballot and that determines how the vote choices are totaled in a given election ballot format The concrete presentation of the contents of a ballot appropriate to the particular voting technology being used The contents may be rendered using various methods of presentation visual or audio language or graphics ballot image Electronically produced record of all votes cast by a single voter See also cast vote record ballot instructions Information provided to the voter during the voting session that describes the procedure for executing a ballot Such material may but need not appear directly on the ballot ballot measure 1 A question that appears on the ballot for approval or rejection 2 A contest on a ballot where the voter may vote yes or no ballot position A specific place in a ballot where a voter's selection for a particular contest may be indicated Positions may be connected to row and column numbers on the face of a voting machine or ballot particular bit positions in a binary record of a ballot for example an electronic ballot image the equivalent in some other form Ballot positions are bound to specific contests and candidate names by the ballot configuration ballot preparation Selecting the specific contests and questions to be contained in a ballot format and related instructions preparing and testing election-specific software containing these selections producing all possible ballot formats and validating the correctness of ballot materials and software containing these selections for an upcoming election ballot production Process of generating ballots for presentation to voters e g printing paper ballots or configuring the ballot presentation on a DRE ballot rotation Process of varying the order of the candidate names within a given contest ballot style See ballot configuration black box testing Testing either functional or non-functional without reference to the internal structure of the component or system border logic Software firmware or hardwired logic that is developed to connect application logic to COTS or third-party logic Note Although it is typically developed by the voting system manufacturer border logic is constrained by the requirements of the third-party or COTS interface with which it must interact It is not always possible for border logic to achieve its function while conforming to coding standards For this reason border logic should be minimized relative to application logic and where possible wrapped in a conforming interface An example of border logic that could not be so A-4 Voting System Performance Guidelines Appendix A wrapped is a customized boot manager that connects a bootable voting application to a COTS BIOS C callable unit Of a software program or analogous logical design Function method operation subroutine procedure or analogous structural unit that appears within a module candidate Person contending in a contest for office A candidate may be explicitly presented as one of the choices on the ballot or may be a write-in candidate candidate register Record that reflects the total votes cast for the candidate This record is augmented as each ballot is cast on a DRE or as digital signals from the conversion of voted paper ballots are logically interpreted and recorded canvass Compilation of election returns and validation of the outcome that forms the basis of the official results by political subdivision cast ballot Ballot that has been deposited by the voter in the ballot box or electronically submitted for tabulation Cast Vote Record CVR Permanent record of all votes produced by a single voter whether in electronic paper or other form Also referred to as ballot image when used to refer to electronic ballots catastrophic system failure Total loss of function or functions such as the loss or unrecoverable corruption of voting data or the failure of an on board battery of volatile memory central count voting system A voting system that tabulates ballots from multiple precincts at a central location Voted ballots are placed into secure storage at the polling place Stored ballots are transported or transmitted to a central counting place which produces the vote count report certification Procedure by which a third party gives written assurance that a product process or service conforms to specified requirements See also state certification and national certification certification testing Testing performed under either national or state certification processes to verify voting system conformance to requirements challenged ballot Ballot provided to an individual who claim they are registered and eligible to vote but whose eligibility or registration status cannot be confirmed when they present themselves to vote Once voted such ballots must be kept separate from other ballots and are not included in the tabulation until after the voter's eligibility is A-5 Voting System Performance Guidelines Appendix A confirmed Michigan is an exception in that they determine voter eligibility before a ballot is issued See also provisional ballot closed primary Primary election in which voters receive a ballot listing only those candidates running for office in the political party with which the voters are affiliated In some states non-partisan contests and ballot issues may be included In some cases political parties may allow unaffiliated voters to vote in their party's primary Common Industry Format CIF Format to be used for summative usability test reporting described in ISO IEC 25062 2006 Common Industry Format CIF for Usability Test Reports completed system response time The time taken from when the voter performs some detectible action to when the voting system completes its response and settles into a stable state e g finishes painting the screen with a new page component Element within a larger system a component can be hardware or software For hardware it is a physical part of a subsystem that can be used to compose larger systems e g circuit boards internal modems processors computer memory For software it is a module of executable code that performs a well-defined function and interacts with other components confidentiality Prevention of unauthorized disclosure of information configuration management Discipline applying technical and administrative direction and surveillance to identify and document functional and physical characteristics of a configuration item control changes to these characteristics record and report change processing and implementation status and verify compliance with specified requirements configuration management plan Document detailing the process for identifying controlling and managing various released items such as code hardware and documentation conformance Fulfillment of specified requirements by a product process or service conformance testing Process of testing an implementation against the requirements specified in one or more standards The outcomes of a conformance test are generally a pass or fail result possibly including reports of problems encountered during the execution Also known as certification testing contest Decision to be made within an election which may be a contest for office or a referendum proposition and or question A single ballot may contain one or more contests COTS Software firmware device or component that is used in the United States by many different people or organizations for many different applications other than certified voting systems and that is incorporated into the voting system with no manufacturer- or application-specific modification Note 1 The expansion of COTS as Commercial Off-The-Shelf is no longer helpful since much of what satisfies the A-6 Voting System Performance Guidelines Appendix A requirements is non-commercial software that is not available in stores The acronym COTS is used here only because it is familiar to the audience 2 By requiring many different applications this definition deliberately prevents any application logic from receiving a COTS designation count Process of totaling votes See tabulation counted ballot Ballot that has been processed and whose votes are included in the candidates and measures vote totals corrective action Action taken to eliminate the causes of an existing deficiency or other undesirable situation in order to prevent recurrence critical failure Functional failure the occurrence of which jeopardizes the validity of the election or casts doubt on the credibility of the election result cross filing Endorsement of a single candidate or slate of candidates by more than one political party The candidate or slate appears on the ballot representing each endorsing political party Also referred to as cross-party endorsement cryptographic key Value used to control cryptographic operations such as decryption encryption signature generation or signature verification cryptography Discipline that embodies the principles means and methods for the transformation of data in order to hide their semantic content prevent their unauthorized use prevent their undetected modification and establish their authenticity cumulative voting A method of voting exclusive to multi-member district election e g county board in which each voter may cast as many votes as there are seats to be filled and may cast two or more of those votes for a single candidate D decertification Revocation of national or state certification of voting system hardware and software decryption Process of changing encrypted text into plain text device Functional unit that performs its assigned tasks as an integrated whole digital signature An asymmetric key operation where the private key is used to digitally sign an electronic document and the public key is used to verify the signature Digital signatures provide data authentication and integrity protection direct-recording electronic DRE voting system Combination Accessible Voting Station and tabulator that gathers votes via an electronic ballot interface records voting data and ballot images in memory components and produces a tabulation of the voting A-7 Voting System Performance Guidelines Appendix A data Note A typical DRE presents contest choices to the voter on an electronic monitor and after the voter finishes the ballot the voter's votes are stored locally on the computer disability With respect to an individual 1 a physical or mental impairment that substantially limits one or more of the major life activities of such individual 2 a record of such an impairment 3 being regarded as having such an impairment definition from the Americans with Disabilities Act dynamic voting system software Software that changes over time once it is installed on the voting equipment See also voting system software E EAC Election Assistance Commission www eac gov early voting Broadly voting conducted before Election Day where the voter completes the ballot in person at a county office or other designated polling place or ballot drop site prior to Election Day election A formal process of selecting a person for public office or of accepting or rejecting a political proposition by voting election databases Data file or set of files that contain geographic information about political subdivisions and boundaries all contests and questions to be included in an election and the candidates for each contest election definition Definition of the contests and questions that will appear on the ballot for a specific election election district Contiguous geographic area represented by a public official who is elected by voters residing within the district boundaries The district may cover an entire state or political subdivision may be a portion of the state or political subdivision or may include portions of more than one political subdivision election management system Set of processing functions and databases within a voting system that defines develops and maintains election databases performs election definitions and setup functions format ballots count votes consolidates and report results and maintains audit trails election officials The people associated with administering and conducting elections including government personnel and poll workers election programming Process by which election officials or their designees use voting system software to logically define the ballot for a specific election A-8 Voting System Performance Guidelines Appendix A electronic ballot interface Subsystem within a voting system which communicates ballot information to a voter in video audio or other alternative format which allows the voter to select candidates and issues by means of vocalization or physical actions electronic cast vote record An electronic version of the cast vote record electronic voting machine Any system that utilizes an electronic component Term is generally used to refer to DREs See also voting equipment voting system electronic voting system An electronic voting system is one or more integrated devices that utilize an electronic component for one or more of the following functions ballot presentation vote capture vote recording and tabulation A DRE is a functionally and physically integrated electronic voting system which provides all four functions electronically in a single device An optical scan also known as marksense system where the voter marks a paper ballot with a marking instrument and then deposits the ballot in a tabulation device is partially electronic in that the paper ballot provides the presentation vote capture and vote recording functions An optical scan system employing a ballot marking device adds a second electronic component for ballot presentation and vote capture functions Electronically-assisted Ballot Marker EBM Accessible Voting Station that produces an executed human-readable paper ballot as a result and that does not make any other lasting record of the voter's votes Note One kind of EBM presents contest choices to the voter on an electronic monitor after the voter finishes the ballot the voter's choices are printed on a paper ballot that is the only record of the voter's choices However vote-bytelephone systems that are in use at the time of this writing are also EBMs The voter uses an audio interface remotely and a paper ballot is produced centrally An EBM may mark ballot positions on a pre-printed ballot or it may print an entire ballot however in any event the ballot produced is assumed to be human-readable and comparable to a manually-marked paper ballot encryption Process of obscuring information by changing plain text into ciphertext for the purpose of security or privacy See also cryptography and decryption error correcting code coding system that allows data being read or transmitted to be checked for errors and when detected corrects those errors F failure Voting system reliability Event that results in a loss of one or more functions b degradation of performance such that the device is unable to perform its intended function for longer than 10 seconds c automatic reset restart or reboot of the voting device operating system or application software d a requirement for an unanticipated intervention by a person in the role of poll worker or technician before normal operation can continue or e error messages and or audit log entries indicating that a failure has occurred Discussion In plain language failures are equipment breakdowns including software crashes such that continued use without service or replacement is worrisome to A-9 Voting System Performance Guidelines Appendix A impossible Normal routine occurrences like running out of paper are not considered failures Misfeeds of ballots into optical scanners are handled by a separate benchmark Requirement 4 1 5 1 f so these are not included as failures for the general reliability benchmark Federal Information Processing Standards Standards for federal computer systems developed by NIST These standards are developed when there are no existing industry standards to address federal requirements for system interoperability portability of data and software and computer security firmware Computer programming stored in programmable read-only memory thus becoming a permanent part of the computing device It is created and tested like software Functional Configuration Audit FCA Exhaustive verification of every system function and combination of functions cited in the manufacturer's documentation The FCA verifies the accuracy and completeness of the system's Voter Manual Operations Procedures Maintenance Procedures and Diagnostic Testing Procedures functional test Test performed to verify or validate the accomplishment of a function or a series of functions G general election Election in which voters regardless of party affiliation are permitted to select candidates to fill public office and vote on ballot issues guidelines See product standard H hash Algorithm that maps a bit string of arbitrary length to a fixed-length bit string hash function A function that maps a bit string of arbitrary length to a fixed length bit string Approved hash functions satisfy the following properties 1 One-way It is computationally infeasible to find any input that maps to any pre-specified output and 2 Collision resistant It is computationally infeasible to find any two distinct inputs that map to the same output hardwired logic Logic implemented through the design of an integrated circuit the programming of a Programmable Logic Device PLD Field-Programmable Gate Array FPGA Peripheral Interface Controller PIC or similar the integration of smaller hardware components or mechanical design e g as in lever machines A-10 Voting System Performance Guidelines Appendix A I implementation statement Statement by a manufacturer indicating the capabilities features and optional functions as well as extensions that have been implemented Also known as implementation conformance statement Independent Testing Authority ITA Replaced by accredited testing laboratories and VSTL Voting System Test Lab Prior usage referred to independent testing organizations accredited by the National Association of State Election Directors NASED to perform voting system qualification testing information security Protecting information and information systems from unauthorized access use disclosure disruption modification or destruction in order to provide integrity confidentiality and availability initial system response time The time taken from when the voter performs some detectible action such as pressing a button to when the voting system begins responding in some obvious way such as an audible response or any change on the screen inspection Examination of a product design product process or installation and determination of its conformity with specific requirements or on the basis of professional judgment with general requirements Inspection of a process may include inspection of staffing facilities technology and methodology integrity Guarding against improper information modification or destruction and ensuring information non-repudiation and authenticity K key management Activities involving the handling of cryptographic keys and other related security parameters e g passwords during the entire life cycle of the keys including their generation storage establishment entry and output and zeroization L logic and accuracy testing Testing of the tabulator setups of a new election definition to ensure that the content correctly reflects the election being held i e contests candidates number to be elected ballot styles and that all voting positions can be voted for the maximum number of eligible candidates and that results are accurately tabulated and reported logical correctness Condition signifying that for a given input a computer program will satisfy the program specification and produce the required output logic defect Fault in software firmware or hardwired logic A-11 Voting System Performance Guidelines Appendix A M marginal mark A marginal mark is a mark within a voting target that does not conform to vendor specifications for a reliably detectable vote The word marginal refers to the limit of what is detectable by an optical scanner not the margin of the page Marks that are outside of voting targets are called extraneous marks Voting targets are defined by specifications provided by the manufacturer marksense System by which votes are recorded by means of marks made in voting response fields designated on one or both faces of a ballot card or series of cards Marksense systems may use an optical scanner or similar sensor to read the ballots Also known as optical scan measure register Record that reflects the total votes cast for and against a specific ballot issue This record is augmented as each ballot is cast on a DRE or as digital signals from the conversion of voted paper ballots are logically interpreted and recorded module Structural unit of software or analogous logical design typically containing several callable units that are tightly coupled Note Modular design requires that intermodule coupling be loose and occur over defined interfaces A module should contain all elements needed to compile or interpret successfully and have limited access to data in other modules A module should be substitutable with another module whose interfaces match the original module In software a module typically corresponds to a single source code file or a source code header file pair In object-oriented languages this typically corresponds to a single class of object multi-seat contest Contest in which multiple candidates can run up to a specified number of seats Voters may vote for no more than the specified number of candidates N NASED National Association of State Election Directors www nased org national certification testing Examination and testing of a voting system to determine if the system complies with the performance and other requirements of the national certification standards and with its own specifications national certification test report Report of results of independent testing of a voting system by a VSTL delivered to the EAC with a recommendation regarding granting a certification number NIST National Institute of Standards and Technology NIST approved An algorithm or technique that for which at least one of the following is true A-12 Voting System Performance Guidelines Appendix A a is specified in a FIPS or NIST Recommendation b is adopted in a FIPS or NIST Recommendation or c is specified in a list of NIST approved security functions e g specified as approved in the annexes of FIPS 140-2 non-partisan office Elected office for which candidates run without political party affiliation non-user-serviceable failure Functional failure that requires the manufacturer or highly trained personnel to repair notice of clarification NOC A Notice of Clarification NOC provides further guidance and explanation on the requirements and procedures of the EAC's Voting System Certification or Voting System Testing Laboratory programs NOCs may be issued pursuant to a clarification request from an EAC voting system test laboratory or an EAC registered manufacturer EAC may also issue NOCs when it determines general clarifications are necessary nonvolatile memory Memory in which information can be stored indefinitely with no power applied ROMs and PROMs are examples of nonvolatile memory NVLAP The National Voluntary Laboratory Accreditation Program operated by NIST O open primary Primary election in which any voters can participate regardless of their political affiliation Some states require voters to publicly declare their choice of party ballot at the polling place after which the poll worker provides or activates the appropriate ballot Other states allow the voters to make their choice of party ballot within the privacy of the voting booth operational environment All software hardware including facilities furnishings and fixtures materials documentation and the interface used by the election personnel maintenance operator poll worker and voter required for voting equipment operations optical scan optical scan system System by which votes are recorded by means of marks made in voting response fields designated on one or both faces of a ballot card or series of cards An optical scan system reads and tabulates ballots usually paper ballots by scanning the ballot and interpreting the contents Also known as marksense overvote Voting for more than the maximum number of selections allowed in a contest A-13 Voting System Performance Guidelines Appendix A P paper-based voting system Voting system that records votes counts votes and tabulates the vote count using one or more ballot cards or paper ballots paper record Paper cast vote record that can be directly verified by a voter See also ballot image cast vote record partisan office An elected office for which candidates run as representatives of a political party personal assistive device A device that is carried or worn by an individual with some physical impairment whose primary purpose is to help compensate for that impairment Physical Configuration Audit PCA Inspection by a VSTL that compares the voting system components submitted for certification testing to the manufacturer's technical documentation and confirms that the documentation submitted meets the national certification requirements Includes witnessing of the build of the executable system to ensure that the certified release is built from the tested components political subdivision Any unit of government such as counties and cities school districts and water and conservation districts having authority to hold elections for public offices or on ballot issues polling location Physical address of a polling place polling place Facility to which voters are assigned to cast in-person ballots precinct Election administration division corresponding to a contiguous geographic area that is the basis for determining which contests and issues the voters legally residing in that area are eligible to vote on precinct count Counting of ballots in the same precinct in which those ballots have been cast Precinct Count Optical Scanner PCOS Optical scanner used as a precinct tabulator Note A PCOS is a special purpose scanner designed to enable the voter to feed his or her own paper ballot--one ballot at a time precinct count voting system A voting system that tabulates ballots at the polling place These systems typically tabulate ballots as they are cast and print the results after the close of polling For DREs and for some paper-based systems these systems provide electronic storage of the vote count and may transmit results to a central location over public telecommunication networks precinct tabulator Tabulator that counts votes at the polling place Note These devices typically tabulate ballots as they are cast and print the results after the close of polls For DREs and some paper-based systems these devices provide electronic storage of the vote A-14 Voting System Performance Guidelines Appendix A count and may transmit results to a central location over public telecommunication networks A tabulator that may be configured for use either in the precinct or in the central location may satisfy the requirements for both Precinct tabulator and Central tabulator precision 1 Extent to which a given set of measurements of the same sample agree with their mean Thus precision is commonly taken to be the standard deviation estimated from sets of duplicate measurements made under conditions of repeatability that is independent test results obtained with the same method on identical test material in the same laboratory or test facility by the same operator using the same equipment within short intervals of time 2 Degree of refinement in measurement or specification especially as represented by the number of digits given primary election Election held to determine which candidate will represent a political party for a given office in the general election Some states have an open primary while others have a closed primary Sometimes elections for nonpartisan offices and ballot issues are held during primary elections primary presidential delegation nomination Primary election in which voters choose the delegates to the presidential nominating conventions allotted to their states by the national party committees privacy The ability to prevent others from determining how an individual voted private key The secret part of an asymmetric key pair that is typically used to digitally sign or decrypt data product standard Standard that specifies requirements to be fulfilled by a product or a group of products to establish its fitness for purpose provisional ballot Ballot provided to individuals who claim they are registered and eligible to vote but whose eligibility or registration status cannot be confirmed when they present themselves to vote Once voted such ballots must be kept separate from other ballots and are not included in the tabulation until after the voter's eligibility is confirmed In some jurisdictions called an affidavit ballot See also challenged ballot public key Public part of an asymmetric key pair that is typically used to verify digital signatures or encrypt data public network direct-recording electronic DRE voting system A DRE that transmits vote counts to a central location over a public telecommunication network Q qualification number A number issued by NASED National Association of State Election Directors to a system that has been tested by an accredited Independent Testing A-15 Voting System Performance Guidelines Appendix A Authority for compliance with the voting system standards Issuance of a qualification number indicates that the system conforms to the national standards qualification test report Report of results of independent testing of a voting system by an Independent Test Authority documenting the specific system configuration tested the scope of tests conducted and when testing was completed qualification testing Examination and testing of a voting system by a NASEDaccredited Independent Test Authority to determine if the system conforms to the performance and other requirements of the national certification standards and the manufacturer's own specifications R ranked order voting Practice that allows voters to rank candidates in a contest in order of choice 1 2 3 and so on A candidate receiving a majority of the first choice votes wins that election If no candidate receives a majority the last place candidate is deleted and all ballots are counted again with each ballot cast for the deleted candidate applied to the next choice candidate listed on the ballot The process of eliminating the last place candidate and recounting the ballots continues until one candidate receives a majority of the vote The practice is also known as instant runoff voting preferences or preferential voting or choice voting recall issue with options Process that allows voters to remove elected representatives from office prior to the expiration of their terms of office The recall may involve not only the question of whether a particular officer should be removed but also the question of naming a successor in the event that there is an affirmative vote for the recall recertification Re-examination and possibly retesting of a voting system that was modified subsequent to receiving national and or state certification The object of recertification is to determine if the system as modified still conforms to the requirements recount Retabulation of the votes cast in an election referendum Process whereby a state law or constitutional amendment may be referred to the voters before it goes into effect reporting context Scope within which reported totals or counts are calculated e g precinct or election district reproducibility Ability to obtain the same test results by using the same test method on identical test items in different testing laboratories with different operators using different equipment requirement Provision that conveys criteria to be fulfilled A-16 Voting System Performance Guidelines Appendix A risk assessment The process of identifying the risks to system security and determining the probability of occurrence the resulting impact and safeguards that would mitigate this impact runoff election Election to select a winner following a primary or a general election in which no candidate in the contest received the required minimum percentage of the votes cast The two candidates receiving the most votes for the contest in question proceed to the runoff election S secure receptacle The container for storing VVPAT paper audit records security analysis An inquiry into the potential existence of security flaws in a voting system Includes an analysis of the system's software firmware and hardware as well as the procedures associated with system development deployment operation and management security controls Management operational and technical controls i e safeguards or countermeasures prescribed for an information system to protect the confidentiality integrity and availability of the system and its information security strength A number associated with the amount of work that is the number of operations that is required to break a cryptographic algorithm or system semi-static voting system software Software that may change in response to the voting equipment on which it is installed or to election-specific programming split precinct A precinct that contains an election district subdivision e g a water district or school board district requiring an additional ballot configuration spoiled ballot Ballot that has been voted but will not be cast state certification State examination and possibly testing of a voting system to determine its compliance with state requirements for voting systems static voting system software Software that does not change based on the election being conducted or the voting equipment upon which it is installed e g executable code straight party voting Mechanism that allows voters to cast a single vote to select all candidates on the ballot from a single political party summative usability testing Evaluation of a product with representative users and tasks designed to measure the usability defined as effectiveness efficiency and satisfaction of the complete product The purpose of a summative test is to evaluate a product through defined measures rather than diagnosis and correction of specific design problems as in formative testing A-17 Voting System Performance Guidelines Appendix A support software Software that aids in the development maintenance or use of other software for example compilers loaders and other utilities symmetric secret encryption algorithm Encryption algorithms using the same secret key for encryption and decryption T tabulation Process of totaling votes See also count tabulator Device that counts votes Note Any distinction between processing individual votes and processing vote totals that resulted from a previous step is not relevant both of these constitute counting votes t-coil Inductive coil used in some hearing aids to allow reception of an audio band magnetic field signal instead of an acoustic signal The magnetic or inductive mode of reception is commonly used in conjunction with telephones auditorium loop systems and other systems that provide the required magnetic field output technical data package Manufacturer documentation relating to the voting system required to be submitted with the system as a precondition of certification testing telecommunications Transmission between or among points specified by the user of information of the user's choosing without change in the form or content of the information as sent and received test Technical operation that consists of the determination of one or more characteristics of a given product process or service according to a specified procedure test campaign Sum of the work by a VSTL on a single product or system from contract through test plan conduct of testing for each requirement including hardware software and systems reporting archiving and responding to issues afterwards testing standard Standard that is concerned with test methods sometimes supplemented with other provisions related to testing such as sampling use of statistical methods or sequence of tests test method Specified technical procedure for performing a test test plan Document created prior to testing that outlines the scope and nature of testing items to be tested test approach resources needed to perform testing test tasks risks and schedule third-party logic Software firmware or hardwired logic that is neither application logic nor COTS e g general-purpose software developed by a third party that is either A-18 Voting System Performance Guidelines Appendix A customized e g ported to a new platform as is Windows CE39 or not widely used or source code generated by a COTS package touch screen voting machine A voting machine that utilizes a computer screen to display the ballot and allows the voter to indicate his or her selections by touching designated locations on the screen U undervote Occurs when the number of choices selected by a voter in a contest is less than the maximum number allowed for that contest or when no selection is made for a single choice contest usability Effectiveness efficiency and satisfaction with which a specified set of users can achieve a specified set of tasks in a particular environment Usability in the context of voting refers to voters being able to cast valid votes as they intended quickly without errors and with confidence that their ballot choices were recorded correctly It also refers to the usability of the setup and operation in the polling place of voting equipment usability testing Encompasses a range of methods that examine how users in the target audience actually interact with a system in contrast to analytic techniques such as usability inspection user-serviceable failure Functional failure that can be remedied by a troubleshooter and or election official using only knowledge found in voting equipment user documentation V valid vote Vote from a ballot or ballot image that is legally acceptable according to state law validation Process of evaluating a system or component during or at the end of the development process to determine whether it satisfies specified requirements verification Process of evaluating a system or component to determine whether the products of a given development phase satisfy the conditions such as specifications imposed at the start of the phase video ballot Electronic ballot interface which presents ballot information and voting instructions as video images See also ballot 39 Specific equipment and materials are identified in order to describe certain procedures In no case does such identification imply recommendation or endorsement nor does it imply that the materials or equipment identified are necessarily the best available for the purpose A-19 Voting System Performance Guidelines Appendix A vote for N of M A multi-seat contest in which voters are allowed to vote for a specified number N of candidates voted ballot Ballot that contains all of a voter's selections and has been cast voter inactivity time The amount of time from when the system completes its response until there is detectible voter activity In particular note that audio prompts from the system may take several minutes and that this time does not count as voter inactivity voter verifiable A voting system feature that provides the voter an opportunity to verify that his or her ballot selections are being recorded correctly before the ballot is cast voter verifiable audit record Human-readable printed record of all of a voter's selections presented to the voter to view and check for accuracy voting device Device that is part of the voting system Note Components and materials that are vital to the function of the voting device within the voting system such as smart cards and ballot printers are considered parts of the device for the purpose of conformity assessment voting equipment All devices including the voting machine used to display the ballot accept voter selections record voter selections and tabulate the votes voting machine The mechanical electromechanical and electric components of a voting system that the voter uses to view the ballot indicate their selections verify their selections In some instances the voting machine also casts and tabulates the votes See voting equipment voting officials Term used to designate the group of people associated with elections including election personnel poll workers ballot designers and those responsible for the installation operation and maintenance of the voting systems voting position Specific response field on a ballot where the voter indicates the selection of a candidate or ballot proposition response voting station The location within a polling place where voters may record their votes A voting station includes the area location booth or enclosure where voting takes place as well as the voting machine See voting machine voting system The total combination of mechanical electromechanical or electronic equipment including the software firmware and documentation required to program control and support the equipment that is used to define ballots to cast and count votes to report or display election results and to maintain and produce any audit trail information and the practices and associated documentation used to identify system components and versions of such components to test the system during its development and maintenance to maintain records of system errors and defects to determine specific system changes to be made to a system after the initial qualification of the system and to make available any materials to the voter such as notices instructions forms or paper ballots Note An Automatic Bar Code Reader is considered part of a voting system A-20 Voting System Performance Guidelines Appendix A based on the definition of a voting system Specifically the Automatic Bar Code Reader supports the system and is used to produce audit trail information therefore it must be included as part of the testing of a voting system 40 voting system software All the executable code and associated configuration files needed for the proper operation of the voting system This includes third party software such as operating systems drivers and database management tools See also dynamic voting system software semi-static voting system software and static voting system software voting system testing Examination and testing of a computerized voting system by using test methods to determine if the system complies with the requirements in the Voluntary Voting System Guidelines and with its own specifications Voting System Test Lab VSTL Test laboratory accredited by the Election Assistance Commission under the EAC's Voting System Testing and Certification Program W white box testing Testing based on an analysis of the internal structure of the component or system write-in voting To make a selection of an individual not listed on the ballot In some jurisdictions voters may do this by using a marking device to physically write their choice on the ballot or they may use a keypad touch screen or other electronic means to enter the name A 2 Sources Definitions in this glossary are either extracted from or based on the following sources 44 U S C 35 United States Code Title 44 Chapter 35 Information Security Section 3542 Definitions ACM SIGCHI ACM's Special Interest Group on Computer-Human Interaction http www acm org sigchi February 2005 ADA Americans with Disabilities Act of 1990 ANSI Dictionary American National Dictionary for Information Processing Systems American National Standards Committee X3 Information Processing Systems 1982 40 The italicized text is based on EAC Decision on Request for Interpretation 2008-08 http www eac gov assets 1 Page EAC%20Decision%20on%20Automatic%20Bar%20Code%20Readers p df A-21 Voting System Performance Guidelines Appendix A ANSI 354 American National Standards Institute International Committee for Information Technology Standards Common Industry Format for Usability Test Reports ANSI INCITS 354-2001 ANSI C63 19 American National Standards for Methods of Measurement of Compatibility between Wireless Communications Devices and Hearing Aids 2001 electionline http electionline org March 2005 FIPS 81 Federal Information Processing Standard 81 DES Modes of Operations December 1980 FIPS 140-2 Federal Information Processing Standard 140-2 Security Requirements for Cryptographic Modules May 2001 FIPS 199 Federal Information Processing Standard 199 Standards for Security Categorization of Federal Information and Information Systems December 2003 FIPS 201 Federal Information Processing Standard 201 Personal Identity Verification for Federal Employees and Contractors February 2005 HAVA Help America Vote Act of 2002 - Public Law 107-252 IEA International Ergonomics Association http www iea cc February 2005 IEEE 1583 IEEE P1583 D5 3 2 Draft Standard for the Evaluation of Voting Equipment December 6 2004 ISO 5725 ISO IEC 5725 1994 Accuracy trueness and precision of measurement methods and results ISO 9241 ISO IEC 9241 1997 Ergonomic requirements for office work with visual display terminals VDT ISO 17000 ISO IEC 17000 2004 Conformity assessment -- Vocabulary and general principles ISO Guide 2-4 ISO IEC Guide 2 2004 Standardization and related activities General vocabulary ISO Guide 2-6 ISO IEC Guide 2 1996 Standardization and related activities General vocabulary A-22 Voting System Performance Guidelines Appendix A NASS National Association of Secretaries of State Election Reform Key Terms http www nass org Election%20Reform%20Key%20Terms pdf February 2005 NIST HB 143 NIST Handbook 143 State Weights and Measures Laboratories Program Handbook NIST HB 150 NIST Handbook 150 2001 NVLAP Procedures and General Requirements NIST HF Rpt NIST Special Publication 500-256 Improving the Usability and Accessibility of Voting Systems and Products May 2004 NIST SP 800-30 NIST Special Publication 800-30 Risk Management Guide for Information Technology Systems July 2002 NIST SP 800-49 NIST Special Publication 800-49 Federal S MIME V3 Client Profile November 2002 NIST SP 800-53 NIST Special Publication 800-53 Recommended Security Controls for Federal Information Systems Appendix B Glossary NIST SP 800-59 NIST Special Publication 800-59 Guideline for Identifying an Information System as a National Security System August 2003 NIST SP 800-63 NIST Special Publication 800-63 Electronic Authentication Guideline Recommendations of the National Institute of Standards and Technology June 2004 OMB A130 OMB Circular A-130 Appendix III Section 508 of the Rehabilitation Act of 1973 as amended Electronic and Information Technology Accessibility Standards 2002 Architectural and Transportation Barriers Compliance Board 36 CRF Part 1194 http www accessboard gov guidelines-and-standards communications-and-it aboutthe-section-508-standards section-508-standards Usability Glossary Usability First Usability Glossary http www usabilityfirst com glossary main February 2005 VIM The ISO International Vocabulary of Basic and General Terms in Metrology VIM 1994 VSS 2002 Voting Systems Standards Volumes I and II Federal Election Commission A-23 Voting System Performance Guidelines Appendix A Whatis com http whatis com IT Encyclopedia A-24 Appendix B References Table of Contents Appendix B B 1 B 2 B 3 B 4 References Documents Incorporated in the Guidelines Other Documents Used in Developing the Guidelines Legislation References Additional References B-1 2 2 4 5 6 Voting System Performance Guidelines Appendix B References Appendix B References B 1 Documents Incorporated in the Guidelines The following publications have been incorporated into the Guidelines When specific provisions from these publications have been incorporated specific references are made in the body of the Guidelines Federal Regulations Code of Federal Regulations Title 29 Part 1910 Occupational Safety and Health Act Code of Federal Regulations Title 36 Part 1194 Architectural and Transportation Barriers Compliance Board Electronic and Information Technology Standards - Final Rule Code of Federal Regulations Title 47 Parts 15 and 18 Rules and Regulations of the Federal Communications Commission Code of Federal Regulations Title 47 Part 15 Radio Frequency Devices Subpart J Computing Devices Rules and Regulations of the Federal Communications Commission International Organization for Standardization ISO ISO 9001 2000 Quality Management Systems - Requirements ISO 10007 2003 Quality Management Systems - Guidelines for Configuration Management ISO 9000 2005 Quality Management Systems - Fundamentals and Vocabulary American National Standards Institute ANSI ANSI C63 4 Methods of Measurement of Radio-Noise Emissions from LowVoltage Electrical and Electronic Equipment in the Range of 9Khz to 40 GHz ANSI C63 19 American National Standard for Methods of Measurement of Compatibility between Wireless Communication Devices and Hearing Aids B-2 Voting System Performance Guidelines Appendix B References ANSI-NCITS 354-2001 Industry Usability Reporting and the Common Industry Format International Electrotechnical Commission IEC IEC 61000-4-2 2008-12 Ed 2 0 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 2 Electrostatic Discharge Immunity Test Basic EMC publication IEC 61000-4-3 1996 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 3 Radiated Radio-Frequency Electromagnetic Field Immunity Test IEC 61000-4-4 2004-07 Ed 2 0 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 4 Electrical Fast Immunity Test IEC 61000-4-5 1995-02 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 5 Surge Immunity Test IEC 61000-4-6 1996-04 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 6 Immunity to Conducted Disturbances Induced by Radio-Frequency Fields IEC 61000-4-8 1993-06 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 8 Power-Frequency Magnetic Field Immunity Test Basic EMC publication IEC 61000-4-11 1994-06 Electromagnetic Compatibility EMC Part 4 Testing and Measurement Techniques Section 11 Voltage Dips Short Interruptions and Voltage Variations Immunity Tests IEC 61000-5-7 Ed 1 0 b 2001 Electromagnetic compatibility EMC Part 5-7 Installation and mitigation guidelines--Degrees of protection provided by enclosures against electromagnetic disturbances National Institute of Standards and Technology FIPS 140-2 Security Requirements for Cryptographic Modules FIPS 180-2 Secure Hash Standard August 2002 FIPS 186-2 Digital Signature Standard February 2000 FIPS 188 Standard Security Label for Information Transfer FIPS 196 Entity Authentication Using Public Key Cryptography B-3 Voting System Performance Guidelines Appendix B References FIPS 197 Advanced Encryption Standard AES SP 800-63 Electronic Authentication Guideline Version 1 0 1 Military Standards MIL-STD-498 Software Development and Documentation Standard 1989 MIL-STD-810D 2 Environmental Test Methods and Engineering Guidelines 19 July 1983 B 2 Other Documents Used in Developing the Guidelines The following publications have been used for guidance in the revision of the Guidelines American National Standards Institute ANSI International Organization for Standardization ISO International Electro-technical Commission IEC ANSI ISO IEC Information Technology Guidelines for the Management of TR 9294 1990Software Documentation IEC UL 60950-1 Information technology-Safety-Part 1 General Requirements ISO IEC 60950-1 Information technology-- Safety--Part 1 General Requirements ISO IEC TR 13335-4 2000 Information technology--Guidelines for the management of IT Security--Part 4 Selection of safeguards ISO IEC TR 13335-3 1998 Information technology--Guidelines for the management of IT Security--Part 3 Techniques for the management of IT security ISO IEC TR 13335-2 1997 Information technology--Guidelines for the management of IT Security--Part 2 Managing and planning IT security ISO IEC TR 13335-1 1996 Information technology--Guidelines for the management of IT Security--Part 1 Concepts and models for IT security ISO IEC 2506206 Common Industry Format CIF for Usability Test Reports Electronic Industries Alliance Standards MB2 MB5 MB9 Maintainability Bulletins EIA 157 Quality Bulletin EIA QB2-QB5 Quality Bulletins B-4 Voting System Performance Guidelines Appendix B References EIA RB9 Failure Mode and Effect Analysis Revision 71 EIA SEB1--SEB4 Safety Engineering Bulletins RS-232-C Interface Between Data Terminal Equipment and Data Communications Equipment Employing Serial Binary Data Interchange RS-366-A Calling Interface Between Data Terminal Equipment and Automatic Equipment for Data Communication RS-404 Standard for Start-Stop Signal Quality Between Data Terminal Equipment and Non-synchronous Data Communication Equipment National Institute of Standards and Technology NIST SP 800-57 NIST Special Publication 800-57 Recommendation for Key Management - Part 1 General NISTIR 7519 Style Guide for Voting System Documentation http www nist gov itl vote upload NISTIR-7519 pdf NISTIR 7537 Guidelines for Using Color in Voting Systems http www nist gov itl vote upload NISTIR-7537 pdf NISTIR 4909 Software Quality Assurance Documentation and Reviews Institute of Electrical and Electronics Engineers 610 12-1990 IEEE Standard Glossary of Software Engineering Terminology 730-1998 IEEE Standard for Software Quality Assurance Plans 828-1998 IEEE Standard for Software Configuration Management Plans 829-1998 IEEE Standard for Software Test Documentation 830-1998 IEEE Recommended Practice for Software Requirements Specifications Military Standards MIL-STD-498 Software Development and Documentation 27 May 1998 B 3 Legislation References Help America Vote Act Pub L 107-252 42 USC Sections 15301-15545 B-5 Voting System Performance Guidelines Appendix B References Americans With Disabilities Act of 1990 Pub L 101-336 42 USC Sections 1210112213 Retention and preservation of records and papers by officers of elections 42 USC 1974 Occupational Safety and Health Act Pub L 91-596 29 USC Sections 651-678 42 USC Section 3142-1 Architectural Barriers Act of 1968 Pub L 90-480 42 USC Sections 4151-4157 Voting Rights Act of 1965 Pub L 89-110 42 USC Sections 1973 1973a-p 1973aa 1973aa-1-6 1973bb 1973bb-1 B 4 Additional References The following publications contain information that is useful in understanding and complying with the Guidelines American National Standards Institute ANSI International Organization for Standardization ISO International Electro-technical Commission IEC ANSI ISO IEC TR 10176 1998 Information Technology Guidelines for the Preparation of Programming Language Standards ANSI ISO IEC 6592 2000 Information Technology Guidelines for the Documentation of Computer Based Application Systems ANSI X9 31-1998 Digital Signatures Using Reversible Public Key Cryptography for the Financial Services Industry 1998 ANSI X9 62-1998 Public Key Cryptography for Financial Services Industry The Elliptic Curve Digital Signature Algorithm 1998 ISO IEC 95948 2001 ITU-T Recommendation X 509 2000 Information technology Open Systems Interconnection - The Directory Public-key and attribute certificate frameworks National Institute of Standards and Technology FIPS 102 Guideline for Computer Security Certification and Accreditation FIPS 112 Password Usage 3 FIPS 113 Computer Data Authentication B-6 Voting System Performance Guidelines Appendix B References Institute of Electrical and Electronics Engineers 488-1987 IEEE Standard Digital Interface for Programmable Instrumentation 796-1983 IEEE Standard Microcomputer System Bus IEEE ANSI Software Engineering Standards 750 1-1995 IEEE Guide for Software Quality Assurance Planning 1008-1987 IEEE Standard for Software Unit Testing 1016-1998 IEEE Recommended Practice for Software Design Descriptions 1012-1998 IEEE Guide for Software Verification and Validation Plans Military Standards MIL-HDBK-454 Standard General Requirements for Electronic Equipment MIL-HDBK-470 Maintainability Program for Systems Equipment MIL-HDBK-781A Handbook for Reliability Test Methods Plans and Environments for Engineering Development Qualification and Production MIL-STD-882 Systems Safety Program Requirements MIL-STD-1472 Human Engineering Design Criteria for Military Systems Equipment and Facilities MIL-STD-973 Configuration Management 30 September 2000 Other References Designing for the Color-Challenged A Challenge by Thomas G Wolfmaier March 1999 Effective Color Contrast Designing for People with Partial Sight and Color Deficiencies by Aries Arditi Ph D http www lighthouse org color_contrast htm Electronic Markup Language EML Version 4 0 Committee Draft Organization for the Advancement of Structured Information Standards OASIS January 24 2005 Guidelines for Writing Clear Instructions and Messages for Voters and Poll Workers http www nist gov itl vote upload 032906PlainLanguageRpt-2 pdf NIST Special Publication 500-256 Improving the Usability and Accessibility of Voting Systems and Products http vote nist gov B-7 Voting System Performance Guidelines Appendix B References RSA Laboratories Technical Note Public Key Cryptographic Standard PKCS #7 Cryptographic Message Syntax Standard November 1 1993 RSA Laboratories Technical Note Extensions and Revisions to PKCS #7 May 13 1997 Technical Guidelines Development Committee TGDC VVSG Recommendations The Americans with Disabilities Act Accessibility Guidelines ADAAG 2202 Access Board http www access-board gov guidelines-and-standards buildings-and-sites aboutthe-ada-standards background adaag B-8                     National Security Archive    Suite 701  Gelman Library  The George Washington University    2130 H Street  NW  Washington  D C  20037    Phone  202 994‐7000  Fax  202 994‐7005  nsarchiv@gwu edu