Memorandum by De La Rue Security Products
(POS 22)
1. EXECUTIVE
SUMMARY
De La Rue plc is a British company listed on
the London Stock Exchange. The company's core business activities
are the printing of banknotes, including for the Bank of England
and some 150 countries worldwide, the manufacture of passports
identity cards and related issuing systems, cash processing equipment,
software and voting systems.
1.1. Sequoia Voting Systems Inc, a subsidiary
in the United States , provides voting systems and a ballot printing
service in the US market. De La Rue Voting Systems (DLRVS) provides
a similar service outside the USA.
1.2. DLRVS has international experience
ranging from the South African elections to working with the United
Nations in countries like Angola and Mozambique. In the United
Kingdom, the company has played an active role in some of the
electoral pilots over the last two years. This included the pilots
for both e-voting and e-counting at the elections in the boroughs
of Basingstoke and Deane, Chester and Newnham in 2002/2003. In
addition to these activities, DLRVS has a dialogue with a number
of other local councils and authorities in support of their efforts
to develop their approach to the all-postal pilots in June 2004.
DLRVS have responded to consultation papers issued by both the
Office of the Deputy Prime Minister (ODPM) and Electoral Commission
and has also submitted contributions to ODPM directly.
1.3. The responses and recommendations set
out in this paper are confined to the company's experience and
given with particular reference to the issues shown in Press Notice
08/2003-04 15 January 2003.
Administration and Cost
Access and Disability Issues
1.4. De La Rue has no relevant experience
to comment on the issues of Impact on Turnout and Voter Choice,
but makes recommendations on all other issues, especially drawing
the Committee's attention to the risks that an all-postal voting
process may incur if the security of the ballot papers is prejudiced,
and proposing alternatives to accommodate those with disabilities.
In addition attention is drawn to the risk inherent in the time
frame required for preparing all-postal pilots.
2. ELECTORAL
FRAUD
Once the mechanism for voting moves outside
the supervision of the electoral officers at the polling station,
for example using the internet, SMS messaging or postal voting,
the risk of fraud is increased by opportunity. Given that postal
voting has to date been restricted in the UK to exemptions by
pre-advised absence, local authority all-postal pilots or for
members of the Armed Forces overseas etc, the evidence of such
fraud is currently limited.
2.1. More widespread use of postal voting,
could proliferate the instances of fraud by those who might wish
to subvert the electoral process for whatever reason. The process
of despatching and retrieving the ballot papers, and the security
of the ballot paper itself are all vulnerable to such criminal
intervention.
2.2. In the light of worldwide experience
in the prevention of fraud and counterfeiting of other high security
documents, it is important that a postal ballot paper is easily
recognised by the voter and the returning officer as genuine.
Public recognition features are commonplace and accepted by the
public in other security documents such as banknotes, gift vouchers
and tickets for entertainment or sports events. The nature of
the security and the levels incorporated within such documents
is generally related to their value and how many times they are
transacted. A banknote will move across many transactions and
a gift voucher is normally only issued and retrieved when cashed
by the recipient. The need for security on these documents is
that once they become familiar to the users, those with criminal
intent will endeavour to undermine them for whatever intent. We
confine our comments on fraud to our knowledge of the vulnerability
of the ballot paper itself.
2.3. Vulnerability of the ballot paper rests
in both the paper itself (the substrate) and the inks that are
printed on it. These contribute to the public recognition of the
ballot paper through both its look and feel. Technology such as
home inkjet printers and copiers can be used to simply generate
copies (counterfeits) and alterations can be made if there is
not a satisfactory balance of security features that can be easily
recognised and confirmed.
2.4. Valuable lessons emerged from the Electoral
Commission's evaluation of the postal voting pilot schemes conducted
in Charnwood Borough and North West Leicestershire District Councils
at the May 2003 elections in relation to ballot paper security:
2.4.1. The watermarks used in the trials
were of different types. One was half tone and the other a "chemical"
watermark. Both watermarks were of a lower specification than
was recommended by Interpol in 1998 for similar security printed
documents.
2.4.2. In both cases, the enhanced security
provided by a watermark was viewed as beneficial but the veracity
of the feature did not appear to have been tested by the discovery
of counterfeited or fraudulently altered ballot papers.
2.5. It is recommended that there is a clear
definition of what the ODPM and Electoral Commission refer to
as a "watermark" in accordance with the Interpol recommendation
of "a mould-made, three-dimensional, multi-tone watermark
of adequate size and quality so that the subject of the watermark
is easily recognisable and there should preferably be no printing
over the watermark" (Interpol-6/FOMON/RES/9-1977-) http://www.interpol.com/public/ICPO/GeneralAssembly/AGN67/Resolutions/AGN67RES11.asp
To assist public recognition a consistent approach should be taken
to both the style and the design of the watermark varying such
design for each election.
2.6. Experience supports another recommendation
in the evaluation of the pilots in respect of print. A simple
printed image on the ballot paper can easily be copied. The prevalence
of the colour copier and inkjet printer has made it easier for
the fraudster to simulate security-printed features. In addition
the Internet provides a wealth of information on how to forge
documents.
2.7. To further obviate the efforts of the
fraudster, it is recommended that other features should also be
incorporated to secure ballot papers such as specialist inks and
if appropriate escalated to optical devices such as holographic
materials and threads in the paper. These need to be blended into
the ballot paper with care otherwise their purpose can be mitigated
by weak design.
3. PUBLIC PERCEPTIONS
Any substantive change in voting practice will
attract challenges to the security and integrity of the process.
The process will only be as strong as its weakest link.
3.1. From experience, public confidence
in the integrity of any security document rapidly weakens if there
is any substantive fraud. If such fraud occurred in postal ballot
papers, it would undermine the confidence of the electorate to
vote in this way with a potentially disastrous effect on turnout.
4. IMPACT ON
TURNOUT
De La Rue has no relevant experience to comment
on voter turnout.
5. ADMINISTRATION
AND COST
5.1. If it is accepted that there is a need
to improve the security of the postal ballot papers as recommended
in Section 2 Electoral Fraud, economies of scale in the bulk purchasing
of either the paper itself or the complete ballot papers should
be encouraged. Most regional authorities have purchasing consortia.
Given the proposed increase in postal voting this approach will
mitigate the costs incurred in the pilots of purchasing on a "one
off" basis. It should also be noted that restricting the
number of paper or complete ballot paper supplier will also have
a beneficial impact on security by enhancing the security of the
supply chain
5.2. Further economies can be achieved through
the use of automation at the counting centres thereby increasing
the speed, accuracy and efficiency of the count, and reducing
the number of people needed.
5.3. By adopting a more centralised approach
to the print, mailing, receipt and validation of returned postal
votes and the implementation of automation in the counting economies
of scale could be achieved through the appropriate pooling of
resources.
5.4. Vote counting automation will have
an impact on the design and features printed on a ballot paper.
Widespread use of automation will drive the need for more commonality
of ballot papers which if coordinated will contribute to cost
reduction.
5.5. By using a watermarked paper, North
West Leicestershire District, incurred more costs but these were
off-set by savings in the time required to administer and operate
the electoral process. In the Charnwood pilot scheme significant
procedural gains were obtained through the use of watermarked
ballots thereby eliminating the need for the traditional stamping
process.
6. ACCESS AND
DISABILITY ISSUES
All postal voting will lead to difficulties
for the partially sighted and the blind unless special consideration
is given to their needs. Conversely those with other disabilities
or confined to their homes may be advantaged by the all-postal
voting.
6.1. The design of the ballot paper is fundamental
if partially sighted people are to engage in the process, and
there are many recommendations available in this area from the
Royal Society for the Blind that are embodied in other documents.
For the totally blind, who have no one to assist them, some provision
needs to be made for them to vote. In the Electoral Commission
report, "The Shape of Elections to Come", (page 37 Accessibility),
it is stated that "Visually impaired people are one such
obvious group but it also includes many people with communication,
neurological, learning and coordination impairments".
Disabled voters must be given the same right of access to vote
without assistance as other groups.
6.2. As part of a complete and equitable
electoral process for all voters, it is recommended that consideration
is given to providing dedicated polling stations with touch screen
systems which have an audio unit attachment that that will assist
the impaired voter through the voting process. In addition standard
interfaces are available to allow for direct voter interaction
using other forms of disability aids such as a breath switch or
other enabling devices used by those with limited or restricted
body movement. Combined with mostly all postal voting, presently
available technology will enable all the electorate to vote according
to choice.
7. VOTER CHOICE
De La Rue has no relevant experience to comment
on voter choice other than the recommendations made in 6.2.
8. TIME FRAME
8.1. In the Electoral Commission report
"The Shape of Elections to Come", (page 86) it makes
the recommendation that "More time is required for suppliers
and local authorities to implement e-voting and e-counting solutions".
This also applies to all-postal schemes especially where economies
of scale offer the opportunity to invest in and implement automated
processes.
8.2. The timescales afforded to local authorities
and suppliers alike, to construct and implement all-postal schemes
for the June 2004 elections are very limited. The legislative
framework needs to be in place in sufficient time to permit both
the local authorities and the suppliers to meet the June 2004
deadline. It is our view that time is already short.
8.3. With the possibility that all-postal
trials may take place in 4 of the UK regions this year, which
will equate to an electorate of 17 million eligible voters, supplier
capacity to react may also be a risk given the lead times on certain
elements of production, especially paper and any automation and
associated systems.
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