EAC - Voluntary Voting System Guidelines

Name : | Jordi Puiggali
Organization : | Scytl Secure Electronic Voting
Post Date : | 9/9/2005
Section Comments
Section : | .20.1.6
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Comment : | Section 1 National Certification Testing Guidelines 4.1.1. General Considerations The testing process described in Section 1.6 (Voting Equipment Submitted by Vendor) states that () “…vendors shall submit for testing the specific system configuration that will be offered to jurisdictions or that comprises the component to be marketed plus the other components with which the vendor recommends that the component be used”. This requirement forces vendors of security components, such as IDV systems, to integrate their solutions with at least one voting system vendor before submiting their solution to any qualification test. As a result, IDV vendors depend on voting system vendors to qualify their solutions which can limit the development and adoption of innovative IDV solutions. In our opinion, the testing standards should allow IDV systems to be qualified independently from a voting system through a pre-qualification process. This pre-qualification should be exclusively based on the security requirements of the IDV systems and should not substitute the overall voting system qualification once the IDV system is finally integrated with a particular voting system. The pre-qualification process for IDV systems could facilitate the adoption of security improvements since it would allow States and Counties to make sure that an IDV system fulfils the VVSG requirements without the need of integrating that IDV system with its voting equipment. To this end, we suggest that the Guidelines include provisions for the certification of IDV systems independent from voting systems.