Estonian Parliamentary Elections 2019 – ODIHR Election Expert Team Final Report – Internet Voting

The Office for Democratic Institutions and Human Rights (ODIHR) is a division of the Organization for Security and Co-operation in Europe.  The ODIHR has produced a report on the 3 March 2019 Estonian Parliamentary Elections.

ODIHR Election Expert Team Final Report – Estonia – Parliamentary Elections 3 March 2019 (PDF)

The ODIHR reviews a wide range of election conduct against international standards.  I will only extract selected parts of their report from section VII. Internet voting.  Numerous issues were identified.

In extracts below, EET = Election Expert Team and SEO = Estonian State Electoral Office.

Internal Attacks

the detection and prevention of internal attacks has been largely omitted. A review of operational and technical frameworks by the ODIHR EET indicates that an internal attacker with privileged access to digital ballots could break the vote secrecy of any voter who published an image of the QR code online, even after the expiry of the code’s validity. This contradicts national legislation and international standards pertaining to vote secrecy.21

RECOMMENDATION: The SEO could develop strategies to mitigate the risk of internal attacks, conduct third-party risk assessments, and publish any findings and audit reports well ahead of the next elections.

21 See Article 1(2) of the Election Act. Paragraph 7.4 of the OSCE Copenhagen Document requires that votes are cast by secret ballot or by equivalent free voting procedure. Paragraph 19 of the Council of Europe Committee of Ministers Recommendation CM/Rec(2017)5 on standards for e-voting requires that “E-voting shall be organized in such a way as to ensure that the secrecy of the vote is respected at all stages of the voting procedure”.

above from page 8 of the report

Software Errors May Cause Election Errors

The Internet voting system is not software independent, meaning that software errors in its components, such as the key generation system or the processor, may cause undetected errors in the election results. Considering publicly available records the system has undergone quality control activities but, contrary to international good practice, no reports were published on the SEO’s website, while updates to the source code were made as recently as three days before election day and well after Internet voting commenced.22

In addition, a limited source code review of the system by the ODIHR EET indicated issues regarding the treatment of concurrency, error handling, and error reporting.

RECOMMENDATION: The SEO could integrate quality assurance activities into the maintenance schedule of the voting solution and publish the security rationale and all quality assurance results, including design review, security analysis, and penetration testing results.

22 Paragraph 42 of the Recommendation CM/Rec(2017)5 on standards for e-voting states that “Before any e-election takes place, the electoral management body shall satisfy itself that the e-voting system is genuine and operates correctly.”

above from page 8 of report

External Auditors Did Not Audit All Operations

A team of external auditors was dispatched to assist the SEO with establishing vote secrecy during the computation of preliminary Internet voting results and the integrity of final Internet voting results by verifying the correctness of the cryptographic shuffle and decryption proofs. The team did not audit other critical operations, most notably the correct transmission of the final aggregation of the decrypted Internet votes.23

RECOMMENDATION: The SEO could strengthen its auditing process by developing a complete strategy and requiring auditors to implement critical auditing tools independently and from scratch.

23 Software independence requires that other operations are also independently audited, such as digital signature checking of all e-votes, removal of all duplicate and other ineligible votes from the digital ballot box, revocation, and anonymization. Paragraph 39 of the Recommendation CM/Rec(2017)5 on standards for e-voting states that “the audit system shall be open and comprehensive, and actively report on potential issues and threats.”

above from page 9

Technical Specifications Need Improvement

some key properties are not precisely formulated and left open to interpretation by the SEO and the vendor tasked to implement the Internet voting system, including minimal acceptable levels of cryptographic strength, and accountability and verifiability requirements. This may negatively impact the system’s overall performance and future innovation. The specifications also lack information about timelines and milestones for software development and deployment, and quality assurance.25

RECOMMENDATION: The technological specifications accompanying the legal framework could define acceptable voting systems in more general terms, but include additional requirements related to cryptographic strength, quality assurance, software development and deployment, as well as accountability and verifiability.

25 The Supreme Court considered two post-election appeals against NEC decisions related to Internet voting. While appeals were rejected, the Court recognized the need for more clear procedures and called for a legal clarification of rules on the implementation of Internet voting, in particular regarding counting and mixing of electronic ballots.

above from page 9

Internet voting at the national level

National-level Internet voting

  • Norway discontinued Internet voting trials in 2014.
  • Australia recommended against Internet voting in 2014.
  • Canada recommended against Internet voting in 2016.  The 2019 national Parliamentary election will have hand-marked paper ballots, counted by hand.
  • Finland studied and recommended against Internet voting in 2017.
  • Lithuania has decided not to proceed with Internet voting in 2019.
  • Switzerland has decided to redesign Internet voting trials, rather than making Internet voting a standard option.  However the Swiss Post system has been “temporarily suspended” after critical errors were found in the source code, and the use of the Geneva system has also been suspended pending a review.

UPDATE 2019-07-07: Swiss Post has made a confusing press release, basically to say that it will continue with its new system and discontinue its old one.  The “new system” is the one that had the public testing.  The public testing in which, through access to the source code outside of the restrictive agreement, three serious flaws in the system were found.

Swiss Post has decided to pool its strengths in the e-voting sector and work solely on the new system with universal verifiability. It plans to make the system available to the cantons for trial operation from 2020. Swiss Post will no longer offer the system that was previously in use.

END UPDATE

Estonia continues to be the only country in the entire world that has national-level Internet voting for all voters (during the advance voting period).  And it has numerous issues with procedures and specifications, as well as low and declining turnout.

Although not directly about Internet voting, also note:

Internet voting in Norway

Norway conducted trials of Internet voting in 2011 and 2013.

Internet voting was discontinued after the trials found no improvement in turnout (including no increase in youth turnout), combined with security concerns.

An archive of reports in Norwegian and English is available: The e-vote trial.

Here are some highlights of the reports:

Evaluation of the e-voting trial in 2011 – English summary of Institutt for Samfunnsforskning (ISF) report

we find no evidence that groups of voters have been mobilized to take part in the election as a result of internet voting.

The analyses, in sum, indicate that the trial did not have an effect on voter turnout.

young voters prefer to walk to the polling station on Election Day. They defined traditional voting as a symbolic and ceremonial act that indicates adultness.

Evaluation of the e-voting trial in 2013 (PDF) – English text begins on p 135 (p 137 in PDF)

In line with previous research, our findings indicate that the trial with internet voting does not lead to increased turnout in elections.

The government announced in 2014 that Internet voting trials would be discontinued.

June 25, 2014 – Internet voting pilot to be discontinued

As there is no broad political desire to introduce internet voting, the Government has concluded that it will would be inappropriate to spend time and money on further pilot projects.

The Institute for Social Research evaluated the pilot project in 2013… The report shows that the voters have limited knowledge about the security mechanisms in the system.

“This shows how important it is that elections are conducted at polling stations where election officials make sure that the principle of free and fair elections and the secrecy of the vote is respected,” says [Minister of Local Government and Modernisation Jan Tore] Sanner.

In Norwegian – Ikke flere forsøk med stemmegivning over Internett

The BBC reported this as E-voting experiments end in Norway amid security fears.


As part of the project, in 2009 there was a report on security.  It notes the added risks from remote voting.

The system is no longer by necessity confined to the local polling station; conceivably it is accessible world-wide, thus increasing the potential number of attackers and attack vectors dramatically.

Also as part of the project, in 2012 there was 196-page report International Experience with E-Voting [with a focus on Internet Voting] (PDF).

Online voting and turnout in the 2019 European Parliamentary elections

I am grateful to Estonia for publishing detailed turnout statistics online on its official government elections website, in Estonian and English.

The 2019 European Parliament elections have completed.  Estonia was the only country to offer online voting.  There were seven days of online voting available during the advance voting period in Estonia, from May 16 to May 22 inclusive.

The turnout (percentage of eligible voters) for online voting was 17.6%.

Over 80% of eligible Estonian voters chose not to vote online.

The total turnout was 37.6%.

The majority of Estonian voters chose to vote on paper.

Estonian turnout increased 1.1%.  But provisional overall European turnout increased over 8%.

Estonian turnout was 37.6%.  But provisional overall European turnout was 50.97%.

Estonia’s neighbour Finland doesn’t vote online.  Provisional turnout in Finland was 40.7%.

Estonia’s neighbour Lithuania doesn’t vote online.  Provisional turnout in Lithuania was 53.08%.

In fact, with no other country in this election permitting online voting, turnout was higher in 19 of the 27 other countries that voted.

European Parliament 2019 provisional turnout
Estonia had lower turnout than 19 of the 27 other countries, lower turnout than overall in Europe, and a lower increase in turnout than overall in Europe.

Online voting doesn’t put Estonia at the top of the pack for turnout.  In fact Estonia was in the bottom third of nations for turnout in the 2019 European Parliamentary elections.

So I don’t know how one could continue to assert that online voting is any kind of solution to increasing turnout.

UPDATE 2019-06-01: I have made a Google Docs spreadsheet of the European Parliamentary elections turnout data, if you want to look at the numbers yourself.  Note that this shows total turnout; as indicated above Estonia votes online and on paper, with the majority voting on paper.  END UPDATE

Data sources:

Previously:
March 5, 2019  Internet voting doesn’t increase turnout in Estonian elections

online voting is destructive modernization

Is Internet voting beneficial modernization, or destructive modernization?

Let’s use an analogy to urban life and urban planning.  I am all for beneficial modernization.

Philadelphia, like all cities before the 20th century, was a hotbed of infectious disease.  Living in a city meant enduring wave after wave of epidemics, and those who could stayed outside the city until the disease burned itself out.

The departure from Quincy took place in the first week of October [1797], but the Adamses were not to reach the capital for more than a month.  Yellow fever again raged in Philadelphia, as they learned en route, so it was necessary to stop and wait at East Chester…

from John Adams by David McCullough

So the sanitation and medical advances that made cities livable were definitely beneficial modernization.

However, modernization can also be destructive.  After the second World War, a wave of “urban renewal” swept over cities, a wave almost as destructive as any epidemic.  The messy diverse urban reality of the city was to be swept away, there was to be a clean slate, everything would be modern and efficient and the car would be unhindered in its rapid progress through the city.

Philadelphia, why Philadelphia was a blank canvas upon which men could draw their geometric visions, without any of the inconvenient reality of poor people, minorities, women, children or the elderly.

Form Design and the City
above from Form, Design and the City (1962)

The city would be clean, modern, efficient.  Le Corbusier looked at Paris and instead of seeing beauty, he saw something he needed to fix.  Here’s his idea for Paris, the Plan Voisin
Plan Voisin model
above by SiefkinDR [CC BY-SA 4.0], via Wikimedia Commons

Robert Moses famously pushed highways throughout urban New York, and as in many parts of the US and Canada, the highways often went through poor neighbourhoods, wiping them out or splitting them permanently in two.  Cars would be convenient, cars would go fast. He was only stopped when he wanted the Lower Manhattan Expressway, stopped in part by Jane Jacobs.

Jane Jacobs wrote about the reality of human behaviour in The Death and Life of Great American Cities

This last point, that the sight of people attracts still other people, is something that city planners and city architectural designers seem to find incomprehensible.  They seem to operate on the premise that city people seek the sight of emptiness, obvious order and quiet.

This is part of her explaining her concept of security through “eyes on the street”.

When we look at online voting–you remember this is about online voting, right?–what we see is exactly those same assumptions, that we should remove people from the equation, that we should make everything orderly and “efficient”.

But voting is not a generic service like paying a parking ticket.  Voting is a complex transaction where you need the paradoxical combination of total privacy and total observation.  Voting is also a social contract where a single vote is transformed into trust in the results of an entire national election.  Voting is about being part of your community.  Voting does not need false notions of convenience and speed.  In order to transmute the individual vote into trust in the entire system, voting needs to move at a human pace under watchful human eyes.  Voting is, in other words, a very human activity.  And so when you move it online, when you drive that highway through the messy line of people waiting to vote, you’re engaged in destructive modernization.

One of the things that “urban renewal” and urban highways did was make life worse for the already underprivileged, and better for the already powerful.  In other words, the white middle-class men who did the planning benefited other white middle-class men.

If we apply this same test to online voting, we find exactly the same thing: the people that actually vote online are the ones who would vote anyway: older male voters.

To put it in the words of What drives fidelity to internet voting? Evidence from the roll–out of internet voting in Switzerland

  • Lower age cohorts are the least likely to remain faithful to internet voting.
  • Senior voters are more likely to remain faithful to internet voting.
  • Gender also has an effect, with women less likely to remain faithful to internet voting.

Or in the rather clearer words of the 2014 BC Independent Panel on Internet Voting

research suggests that Internet voting does not generally cause nonvoters to vote. Instead, Internet voting is mostly used as a tool of convenience for individuals who have already decided to vote.

(See Online voting doesn’t increase turnout for more information on who actually votes online.)

So basically online voting removes the diverse participation and personal experience of casting your ballot on paper, it removes the “eyes on the street” of being able to see the process right in front of you (including the ability of scrutineers to watch the ballots being counted), and it benefits the already empowered people who would have voted anyway. It’s destructive modernization.

Swiss voting technology law sets the standard, in theory

Switzerland – Federal Chancellery Ordinance on Electronic Voting 161.116 of 13 December 2013 (Status as of 1 July 2018)

Key Concepts in Theory

  • the system must be independently evaluated (Article 7, item 1)
  • risk must be assessed (Article 3)
  • the system must be evaluated against detailed requirements (Article 2, section a, Article 4, Article 7, item 2 and item 3)
  • the source code must be made available (Article 7a and Article 7b)

Also notable is that the default maximum authorised participation in electronic voting is 30%.  From above 30% to 50% additional requirements apply, and above 50% even more requirements apply.

In Practice

Unfortunately in practice, for a 2019 public intrusion test, the conditions on both the general testing and the availability of source code were restrictive.

There was not in any sense either unrestricted public testing nor unrestricted publically available open source code.

(If you’ve heard that the tested voting system was withdrawn when serious security flaws were found, this is true, but discovery of these security flaws happened through access to the source code outside of the restrictive agreement.)

My Recommendations

The Swiss ordinance has model principles that should be adopted for evaluating online voting.  In particular independent public evaluation and availability of public source code are key (although keep in mind that source code availability doesn’t mean perfect confidence in the code that actually runs).

The Swiss law is however too complex, and it allowed the interpretation loopholes that led to restrictive terms of use in practice.

Therefore the model principles for evaluating online voting must also include clear language on unrestricted public testing and unrestricted public access to source code.

It’s also important that the independent testing include not just funded open hacking competitions (which are useful) but also direct funding to academic research groups.  The cryptography used in modern voting systems is extraordinarily complex; the academics who are expert in it don’t have free time and don’t work for free.

(Even with academics funded to study the voting system, be mindful that nation-state attackers have far more time and resources to devote to finding flaws in systems, as well as having arsenals of zero-day attacks they could choose to deploy during an election.)

Detailed Technical Language

Below are extracts of the technical language from the ordinance.

Voting System Must Meet Requirements

Art 2. … The authorisation for electronic voting in any individual ballot shall be granted provided the following requirements are met:

a.
The system for electronic voting (the system) is implemented and operated so as to guarantee secure and trustworthy vote casting (Annex No 2 and 3).

There Must Be A Risk Assessment

Art 3. … By the means of a risk assessment, the canton must document in detailed and understandable terms that any security risks are within adequate limits. The assessment covers the following security objectives:

a.
the accuracy of the result;
b.
the protection of voting secrecy and non-disclosure of early provisional results;
c.
the availability of functionalities;
d.
the protection of personal information about voters;
e.
the protection of voter information against manipulation;
f.
the non-disclosure of evidence of vote casting behaviour.

Progressively Higher Requirements As Authorised Participation Increases

The ordinance takes an unusual approach which is to set progressively higher bars to increased availability of online voting. By default, the maximum percentage of the Swiss electorate allowed to use online voting is 30 percent (30%).

At 30% participation there is a minimum set of validation requirements

Art 7. 3If no more than 30 per cent of the cantonal electorate are to be authorised to participate in a trial and the system has the property of complete verifiability in terms of Article 5, the system and its operation must be examined in particular detail with regard to the following criteria:

a.
cryptographic protocol (Annex No 5.1);
b.
functionality (Annex No 5.2), whereby the examination may exclude the software in portals of authorities that are linked to a system;
c.
security of infrastructure and operation (Annex No 5.3), whereby the examination may be limited to the infrastructure that registers the vote and creates the proof for the voter in accordance with Article 4 paragraph 2;
d.
protection against attempts to infiltrate the infrastructure (Annex No 5.5);
e.
control components (Annex No 5.4).2

To exceed 30%

Art 4.1If a system is to be authorised to cover more than 30 per cent of the cantonal electorate, the voters must be able to ascertain whether their vote has been manipulated or intercepted on the user platform or during transmission (individual verifiability, Annex No 4.1 and 4.2).

along with other conditions

Above 30% participation there are also different validation requirements

Art 7. 2If more than 30 per cent of the cantonal electorate are to be authorised to participate in a trial (Art. 4 and 5), the system and its operation must be examined in particular detail with regard to the following criteria:

a.
cryptographic records (Annex No 5.1);
b.
functionality (Annex No 5.2);
c.
security of infrastructure and operation (Annex No 5.3);
d.
protection against attempts to infiltrate the infrastructure (Annex No 5.5);
e.
requirements for printing offices (Annex No 5.6);
f.1
when using a system has the property of complete verifiability in terms of Article 5: control components (Annex No 5.4).

To exceed 50%

Art 5.1If a system is to be authorised to cover more than 50 per cent of the cantonal electorate, it must be ensured that voters or the auditors are able, subject to compliance with voting secrecy, to identify any manipulation that leads to falsification of the result (complete verifiability, Annex No 4.3 and 4.4).

along with other conditions

Independent Assessment

Art. 7 Requirements for examinations

1 The cantons shall ensure that meeting the requirements is examined by independent agencies. The examination is made in particular if the system or its operation has been changed in such a way that meeting the requirements for authorisation could be called into question.

Publication of Source Code

Publication of source code is required, but it’s tangled in the level of authorised participation and in other attributes, so I will just include the entire section

Art. 7a1Publication of the source code

1 The source code for the system software must be made public.

2 Publication shall take place when the system has the property of complete verifiability in terms of Article 5, and:

a.
following the examination in accordance with Article 7 paragraph 2 if more than 30 per cent of the cantonal electorate are to be authorised to participate in a trial;
b.
following the examination in terms of Article 7 paragraph 3 if no more than 30 per cent of the cantonal electorate are to be authorised to participate in a trial.

3 There is no requirement to publish the source code of the following:

a.
third-party components such as operating systems, databases, web and application servers, rights management systems, firewalls or routers, provided these are freely available and regularly updated;
b.
portals of authorities that are linked to a system.

1 Inserted by No I of the FCh O of 30 May 2018, in force since 1 July 2018 (AS 2018 2279).

Art. 7b1Modalities for publishing the source code

1 The source code must be prepared and documented according to the best practices.

2 It must be easily obtainable, free of charge, on the internet.

3 The documentation on the system and its operation must explain the relevance of the individual components of the source code for the security of electronic voting. The documentation must be published along with the source code.

4 Anyone is entitled to examine, modify, compile and execute the source code for ideational purposes, and to write and publish studies thereon. The owner of the source code may permit its use for other purposes.

1 Inserted by No I of the FCh O of 30 May 2018, in force since 1 July 2018 (AS 2018 2279).

Official Versions

As English is not an official language of Switzerland, the annexes to the ordinance and explanations about the ordinance are available only in German, French and Italian.  The annexes provide additional technical detail and there was also an explanatory report produced in 2018 providing context about the need to publish the source code.

UPDATE 2019-05-24: Also see the E-voting home pages and policy pages for each language

Elections Ontario recommends establishing standards and certification for elections technology

In Ontario, there are no standards in place for choosing, testing, certifying or auditing election technology, including the online voting used in Ontario municipal elections.

This is a huge gap that has opened the door to what is currently basically an unregulated process where individual municipalities choose whether or not to use Internet voting and then procure vendor-based solutions without any guidance.

It is therefore heartening to see Elections Ontario recognize this gap in its Report on Ontario’s 42nd General Election (Modernizing Ontario’s Electoral Process, June 7, 2018).  Elections Ontario makes a long recommendation which I am going to quote in full

Establish common evaluative standards and a certification process for election technology

The Chief Electoral Officer recommends that Ontario establish common evaluative standards and a certification process for technology used in the electoral process in Ontario.

Technology holds a lot of promise for the elections of the future. Increasingly, Ontarians expect that technology will be used to make voting easier, offer more choice to electors for when, where and how to vote, and find efficiencies in the electoral process. Electoral management bodies, including Elections Ontario, are increasingly turning to technology to solve logistical challenges.

In Ontario, the adoption of technology into the electoral process has been done in an ad-hoc way since the late 1980s, and has been led by municipalities. This approach made sense when voting technologies were new and there were no best practices from which to draw. It also allowed municipalities to pioneer technology and discover fit-for-purpose solutions to address their local needs.

With more than 20 years of practical experience at hand, we are at a point where we are actively learning from our past so that we can create best practices and develop future guidelines. Standards can provide consistent guidance for municipalities and the province as we adopt proven technologies using a principled and measured approach.

It is critical that our approach to technology be intentional and evidence-based. Even as the public expects electoral management bodies to find efficiencies through technology, they are also increasingly aware of the possible failures of technology. While there are many benefits to using technology, there are risks involved, as illustrated by recent failures of systems at large organizations.

As the public becomes more informed about software, malware and manipulation of technology data systems, they are increasingly interested in knowing exactly how election technology preserves the integrity of our electoral process and the confidentiality of their personal information. For the public to trust the integrity of the electoral process they must be assured that:

  • Technology used to cast a vote will accurately count the vote as intended.
  • Technology used to cast a vote will uphold the secrecy of the vote.
  • Technology used to tabulate votes will be verifiable and protected from tampering.
  • Technology used to transmit election results will be verifiable and protected from tampering.
  • Technology will not result in the breach of their confidential and personal information.

To ensure we maintain public trust in our electoral system as we adopt technology, the Chief Electoral Officer recommends that Ontario establish a set of common evaluative standards and guidelines. These will advise election administrators as they consider which technology to adopt, how to evaluate the technology, and the specific technical standards to consider for adopted technology.

This is a very significant step forward for Elections Ontario.  In particular I laud the phrase “It is critical that our approach to technology be intentional and evidence-based.”

There is also a strong statement of principles at the end of the report

We continue to balance making voting easier for Ontarians with the need to preserve the integrity of the electoral process. We want to provide modernized, flexible, and convenient ways to vote, but cannot compromise the core covenants of our democracy: accessibility, one vote per elector, secrecy, integrity and security. As we continue on this modernization journey, these values will continue to be at the centre of the work we do.

As a starting point, the principles above are very good, and to them I would add the implementation criteria from Ontario’s own 2013 report on Alternative Voting Technologies.

Our implementation criteria are:

  • Accessibility:
    The voting process is equally accessible to all eligible voters, including voters with disabilities. The voting process will be performed by the voter without requiring any assistance for making their selections.
  • Individual verifiability:
    The voting process will provide means for the voter to verify that their vote has been properly deposited inside the virtual ballot box.
  • One vote per voter:
    Only one vote per voter is counted for obtaining the election results. This will be fulfilled even in the case where the voter is allowed to cast their vote on multiple occasions (in some systems, people can cast their vote multiple times, with only the last one being counted).
  • Voter authentication and authorization:
    The electoral process will ensure that before allowing a voter to cast a vote, that the identity of the voter is the same as claimed, and that the elector is eligible to vote.
  • Only count votes from valid voters:
    The electoral process shall ensure that the votes used in the counting process are the ones cast by valid eligible voters.
  • Voter privacy:
    The voting process will prevent at any stage of the election the ability to connect a voter and the ballots cast by the voter.
  • Results validation:
    The voting process will provide means for verifying if the results clearly represent the intention of the voters that participated in the voting process.
  • Service availability:
    The election process and any of its critical components (e.g., voters list information, cast votes, voting channel, etc.) will be available as required to voters, election managers, observers or any other actor involved in the process.

However, those principles need to be refined for a computer-based system, which the report also does

If the implementation of the network voting system does not both support the Chain of Trust and provide auditable evidence, then the process is open to question. This Chain of Trust is a compilation of all the following measures:

  1. Source code audit to verify that the code will do only what it is intended to do.
  2. Digital signature of the audited source code to protect its authenticity and integrity.
  3. Trusted build of the executable code in front of auditors (based on audited source code).
  4. Signature of the executable code to protect its authenticity and integrity.
  5. Deployment of the executable software in a clean system. Logical sealing of the system to detect any later additions.
  6. Logic and accuracy testing of the voting system to validate it works properly.
  7. Continuous audit of the voting system during the election, through review and validation of logs and other data. The logs must be protected from external manipulations by using cryptographic measures.
  8. Post-election audit that validates that the system behaved correctly by reviewing the logical seals and the protected logs.
  9. Individual voter verification that proves their ballots were used in the final tally (by using special receipts).

A strong emphasis must be placed on audit. Independent auditors must be able to review the source code, verify the build and deployment, audit system logs during the election event, and finally to review both the counting process and the results.

Those are strong starting points, and even more so because they emerge from Ontario’s own multi-year research into the subject.
That being said, Ontario also needs to heed the conclusion of the Alternative Voting Technologies report:

At this point, we do not have a viable method of network voting that meets our criteria and protects the integrity of the electoral process.

It is possible that the introduction of standards for municipal online voting could open the door to provincial online voting, and indeed the very-high-level Elections Ontario Strategic Plan 2019 – 2023 (PDF) says

Advance modern elections in a measured and principled manner

  • Assess and analyze the environment to inform the modernization of future elections.
  • Better understand electors’ needs and behaviours to build modern and responsive services.
  • Recommend legislative change to support modernization of electoral services.
  • Pilot modernization initiatives through by-elections.

It’s not at all clear what this “modernization” might include.

Conclusion

It is critical that both the current deployment and any potential further expansion of online voting should be subject to extensive analysis by computer security experts.

By applying an evidence-based approach to technology with extensive public, independent, unrestricted testing of election technology, Elections Ontario has the opportunity to move from what it acknowledges has been an ad-hoc approach to one that brings the appropriate levels of standards, testing, certification and auditing in what is a high-risk cybersecurity environment.

Additionally, Elections Ontario needs to close an auditing gap by putting in place risk-limiting audits for the computer vote counting it is now using for provincial elections.  We cannot simply trust the counts produced by the vote tabulators (because computers can be programmed to produce whatever result the programmer wants); we must have a public audit to increase the confidence in the results.

I hope that municipalities and the provincial government will accept that putting standards in place may result in the decertification and withdrawal of voting technology, as has happened when “electronic voting machines” were examined in the United States and when Switzerland made one of its online voting solutions available for public testing.