Testimony on Guidelines for Implentation of VRD

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U.S. Election Assistance Commission Hearing Regarding
“Proposed Voluntary Guidance on Implementation of
Statewide Voter Registration Lists”

April 26, 2005

Testimony of ACM Committee on Guidelines for
Implementation of Voter Registration Databases


We thank you for holding this public hearing and for considering our comments on the

Help America Vote Act's (HAVA) mandate that all states have statewide computerized

voter-registration databases installed by January 1, 2006. As members of a recently

commissioned study by the Association for Computing Machinery (ACM), we write to

inform you about our work and about some of the critical technical issues that should be

considered in implementing such centralized, potentially vulnerable databases.

ACM is widely recognized as the premier organization for computing professionals,

delivering resources that advance the computing and IT disciplines, enable professional

development, and promote policies and research that benefit society. Members of ACM

have become concerned about potential risks with the HAVA-mandated centralized

voter-registration lists.

ACM commissioned our study to devise technical guidelines intended to help election

officials make voter registration databases reliable and secure, while preserving privacy

to the extent permitted by law and policy. We recognize that such centralized statewide

databases introduce new risks into the voting process. We hope to inform the Election

Assistance Commission (EAC) and state election officials on how to address these risks

within the framework of HAVA’s requirements and the Commission’s guidelines.

Reliability is a constant problem in the implementation of information systems, especially

databases with extremely non-uniform use. Voter registration databases are subject to

large variations in access levels depending on events in the registration/voting process.

Databases with such heavily skewed access are difficult to design, and with the additional

levels of network and system components there is an increased chance of system failure.

Reports abound of voter registration databases not working or being too slow to be useful

on Election Day, 2004. There are known techniques to maximize the reliability of the

systems. Prof. Chris Clifton (Computer Science, Purdue), Dr. Paula Hawthorn (retired

database company executive), and Lillie Coney (Associate Director, Electronic Privacy

Information Center) are producing guidelines for reliability.

Protecting the accuracy and integrity of these databases and their outputs is another

critical factor that we will address. Since centrally managed voter-registration databases

will be tempting targets for hackers, our guidelines for accuracy and integrity will include

protection against improper updates (including by authorized users). They will also

include recommendations for transparency and accountability, both of which are critical

aspects of database accuracy and integrity. The group producing the guidelines for

accuracy and integrity consists of Dr. Rebecca N. Wright (Computer Science, Stevens

Institute of Technology), Dr. Arnon Rosenthal (Research Scientist, MITRE Corporation),

Prof. David Wagner (Electrical Engineering and Computer Science, UC Berkeley), Ralph

Spencer Poore (Consultant, Privacy and Security), and Dr. Steven M. Bellovin

(Computer Science, Columbia).

We are also concerned about the privacy implications of voter registration databases. As

centralized repositories of sensitive data, these databases create new opportunities for

identity theft and lesser forms of harassment. Our guidelines for protecting voter privacy

will discuss policy considerations, access control, legal requirements, and new privacy

risks. Dr. Barbara Simons (retired, IBM Research and former ACM President), Robert

Gellman (privacy and security consultant), Dr. Harry Hochheiser (Computer

Professionals for Social Responsibility), Lillie Coney, Ralph Spencer Poore, and Dr.

Arnon Rosenthal will produce the privacy guidelines.

We anticipate that our guidelines will be completed by Fall 2005; however, we are

planning to provide specific comments on the EAC’s draft guidance by the comment

deadline of May 25. We encourage those who would like more information or would like

to discuss our work to contact Cameron Wilson, Director of Public Policy for ACM, at

(202) 225-9711. We have also attached biographical information on our committee


Thank you again for considering our testimony.

Biographical Information for Members of the ACM Committee

Co-Chair of the Committee, Paula Hawthorn, Ph.D.

Dr. Hawthorn received her Ph.D. in Electrical Engineering and Computer Science from

the University of California in 1979. Her thesis topic was on the performance of database

systems. She has spent much of her career as a manager of database development,

including Vice-President of Software Development for start-ups such as Britton Lee and

Illustra, and both management and individual contributor positions at Hewlett-Packard

(working on database performance issues) and Lawrence Berkeley National Laboratory.

She is now mostly retired, with occasional consulting and continuing involvement with

UC Berkeley.

Co-Chair of the Committee, Barbara Simons, Ph.D.

Dr. Simons earned her Ph.D. from U.C. Berkeley, and was a computer science researcher

at IBM Research, where she worked on compiler optimization, algorithm analysis, and

scheduling theory. A former President of the Association for Computing Machinery

(ACM), Simons founded ACM’s US Public Policy Committee (USACM) and served for

many years as chair or co-chair of USACM. She was a member of the NSF panel on

Internet Voting, the security peer review group for the DoD’s Internet voting project

(SERVE), the President’s Export Council’s Subcommittee on Encryption. She is on

several Boards of Directors, including the U.C. Berkeley Engineering Fund and the

Electronic Privacy Information Center, as well as the Advisory Board of the Oxford

Internet Institute and the Public Interest Registry’s .ORG Advisory Council. She has

testified before both the U.S. and the California legislatures.

Steven M. Bellovin, Ph.D.

Dr. Bellovin is a Professor of Computer Science at Columbia University. He recently

joined the faculty after many years at Bell Labs and AT&T Labs Research. He is an

AT&T Fellow and a member of the National Academy of Engineering. Dr. Bellovin is

the coauthor of Firewalls and Internet Security: Repelling the Wily Hacker (2d ed. 2003),

and holds several patents on cryptographic and network protocols. He has served on

many National Research Council (NRC) study committees, and is a member of the

Department of Homeland Security’s Science and Technology Advisory Committee. He

has been a member of the Internet Architecture Board and co-director of the Security

Area of the Internet Engineering Task Force.

David Wagner, Ph.D.

Professor Wagner is an Assistant Professor in the Computer Science Division at the

University of California at Berkeley with extensive experience in computer security and

cryptography. David is an Alfred P. Sloan Research Fellow and a CRA Digital

Government Fellow. David was a co-designer of one of the Advanced Encryption

Standard finalists, and he remains active in the areas of computer security, cryptography,

and e-voting. In the past, David has served as a member of the Security Peer Review

Group for the SERVE Internet voting project and as a technical advisor to the ACLU Ad-

Hoc Committee on Touchscreen Voting; currently, David is a member of the California

Secretary of State's Technical Advisory Board.

Arnie Rosenthal, Ph.D

Dr. Rosenthal is a Principal Scientist at The MITRE Corporation, working on databases

and distributed systems. In recent years, his research and consulting has focused on data

sharing, privacy and security. He received a Ph.D. in 1974 from University of California

(Berkeley). He was on the faculty of the University of Michigan and worked at Sperry

Research and Computer Corporation of America. He has held visiting positions at the

Swiss Federal Polytechnic (ETH Zurich) and IBM Research.

Rebecca N. Wright, Ph.D.

Dr. Wright is an Associate Professor in the Computer Science Department at Stevens

Institute of Technology in Hoboken, New Jersey. Her research spans the area of

information security, including cryptography, privacy, foundations of computer security,

and fault-tolerant distributed computing. Dr. Wright serves as an editor of the Journal of

Computer Security (IOS Press) and the International Journal of Information and

Computer Security (Inderscience), and is a member of the board of directors of the

International Association for Cryptologic Research. She was Program Chair of Financial

Cryptography 2003 and General Chair of Crypto 2002, and has served on numerous

program committees, including Crypto, the ACM SIGKDD International Conference on

Knowledge Discovery and Data Mining, and the ACM Conference on Computer and

Communications Security. She received a Ph.D. in Computer Science from Yale

University in 1994 and a B.A. from Columbia University in 1988. She is a member of

the IEEE, the ACM, and the IACR.

Chris Clifton, Ph.D.

Professor Clifton has a Ph.D. in Computer Science from Princeton University, and

Bachelor's and Master's degrees from the Massachusetts Institute of Technology. He first

worked on reliability and availability of database systems at IBM Research in the 1980s.

He also worked on data mining and database security issues while at the MITRE

Corporation, and more recently has been leading research on privacy-preserving data

mining since joining the faculty of Purdue University.

Bob Gellman

Robert Gellman is a privacy and information-policy consultant in Washington, D.C. He

advises companies, government agencies and other institutions on how to address privacy

concerns on the Internet, implement the federal medical-privacy rules, and integrate

privacy law and policy in their national and international operations. A graduate of Yale

Law School, Gellman has worked on information-policy issues for more than 25 years.

He spent 17 years as chief counsel to a subcommittee in the U.S. House of

Representatives responsible for privacy, freedom of information, government information

dissemination, health-record confidentiality and other information-policy matters. He also

served as a member of the U.S. Department of Health and Human Service’s National

Committee on Vital and Health Statistics (1996-2000), a federal advisory committee with

responsibilities for health-information infrastructure matters, including the Health

Insurance Portability and Accountability Act.

Lillie Coney

Ms. Coney is Associate Director with the Electronic Privacy Information Center (EPIC).

Her issue areas include, but are not limited to, nanotechnology, surveillance, civil rights

and privacy, census, voter privacy, and electronic voting. The Electronic Privacy

Information Center (EPIC) is a public interest research center in Washington, D.C. It

was established in 1994 to focus public attention on emerging civil liberties issues and to

protect privacy, the First Amendment, and constitutional values. Ms. Coney also serves

as Coordinator of the recently established National Committee on Voting Integrity

(NCVI). NCVI was created in 2003 in response to growing concerns about the reliability

of electronic voting systems.

Ralph Spencer Poore

Ralph Spencer Poore (Principal Consultant at Inovè LLC and Senior Partner at Pi "R"

Squared Consulting LLP) has over thirty years of information technology experience

with emphasis on privacy, security, audit, and control in electronic commerce, enterprise

systems, and enabling technologies. His involvement in national and international

standards for electronic commerce includes participation on two Internet Engineering

Task Force (IETF) working groups and chairmanship of an ad hoc working group of the

Accredited Standards Committee X9, Financial Services, subcommittee X9F Data and

Information Security. He founded and chaired the Standards Review Committee of the

Information Systems Security Association (ISSA) and participates on the Global

Executive Committee of the Generally Accepted Information Security Principles

(GAISP) Committee. Ralph has developed and patented security and privacy products,

taught cryptographic security courses, and provided assurance services across a broad

range of private sector and governmental organizations. He is an inventor, author and

frequent speaker on topics ranging from Privacy to Transnational Border Data Flows.

Ralph is a Certified Fraud Examiner (CFE), Certified Information Systems Auditor

(CISA), Certified Information Systems Security Professional (CISSP), and Certified in

Homeland Security-Level III (CHS-III).

Harry Hochheiser, Ph.D.

Dr. Hochheiser received his Ph.D. in Computer Science from the University of Maryland,

where his research interests included information visualization, bioinformatics, humancomputer

interaction, and the privacy-related systems. A former member of the board of

directors of the Computer Professionals for Social Responsibility (CSPR), Dr.

Hochheiser wrote CPSR's FAQ on Internet filtering systems. He has also written about

the policy implications of Internet privacy protocols. He is a founding member of the

ACM SIGCHI committee on US Public Policy. Dr. Hochheiser is currently working at

the National Institute on Aging developing tools for large-scale analysis of microscopy

images in cell biology.

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