Responses to the Audit
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- County of Santa Clara
- California Secretary of State
County of Santa Clara
October 2, 2017
Ms. Elaine M. Howle, State Auditor
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Dear Ms. Howle:
Please accept this letter as the County of Santa Clara’s response to the California State Auditor’s report entitled, “Santa Clara County Registrar of Voters: Insufficient Policies and Procedures Have Led to Errors That May Have Reduced Voters’ Confidence in the Registrar’s Office.” This audit was conducted at the direction of the Joint Legislative Audit Committee of the California Legislature. We note that the copy of the audit report provided to us omitted certain redacted material. We cannot, and do not, provide a response as to redacted material in the report, and these responses do not address or apply to the redacted items.
The audit report has helped to clarify that, while the County of Santa Clara’s existing documentation and practices comply with relevant legal requirements, its policies, procedures, and practices can be improved to more fully identify and prevent errors in election-related materials.
The audit report should also be commended for making great efforts to explain the complexities of elections and ballot creation processes within a compressed timeframe, as illustrated by Figure 1. The County of Santa Clara strives for complete accuracy in the information it provides to voters, and recognizes that more detailed procedures, process enhancements, and technological advancements would help improve the process of election-related materials creation, verification, and distribution.
The following are the ten recommendations of the audit report, each followed by the County’s response:
To ensure the accuracy of voting district boundaries and to allow Santa Clara to make changes to existing boundaries as necessary, Santa Clara should establish a procedure requiring Mapping staff to ask each voting district either to certify that its boundaries are accurate and unchanged or to provide an updated map of its boundaries at least 125 days before each general district election.
County of Santa Clara Response to Recommendation #1
The County of Santa Clara agrees that staff should request that voting districts confirm that the information the County has is accurate, or provide an updated map of boundaries. The County has an existing process in which annual notices are mailed to local voting districts to request boundary update information. This notification letter includes a verification form by which voting district staff may sign off that the map on file with the Registrar’s Office is accurate and current, in lieu of providing a map to the department for each election. The County agrees that a more complete notice package of information to each of the districts would enhance the process, specifically by including the existing map on file as an enclosure to the annual letter and verification form, and by following up with voting districts that do not respond to the notice.
Santa Clara should immediately coordinate with Information Services to access the most current maps from other county departments, such as the Santa Clara Assessor’s Office, to verify the accuracy of district maps.
County of Santa Clara Response to Recommendation #2
The County of Santa Clara agrees with the recommendation, and has initiated the process of coordinating with Information Services to gain more frequent and regular access to the maps maintained by the County of Santa Clara Assessor’s Office.
To reduce errors and potentially its workload, Santa Clara should research by January 2018 its opportunities to integrate mapping software with its election management software, and Santa Clara should implement this integration of mapping software technology by June 2018.
County of Santa Clara Response to Recommendation #3
The County of Santa Clara agrees with the recommendation to research opportunities to integrate mapping software with its election management system. The County’s election management system software requires a manual data transfer from the County’s Geographic Information Systems software. The County agrees that the extent to which this process can be automated would reduce staff workload and the chance of data entry error. Any changes to the election management system software would need to be agreed upon and developed by the third-party vendor, which would determine the delivery schedule. However, the County agrees with exploring such integration, and, if possible, will attempt to implement by the recommended date.
Santa Clara should promptly seek compensation from its vendors for all costs associated with rectifying vendor errors that occur in the future.
County of Santa Clara Response to Recommendation #4
The County of Santa Clara agrees with this recommendation, to the extent that its agreements with vendors permit such compensation. When past errors resulted from a vendor’s mistake, the County addressed the situation with the vendor’s representatives, asking for the work to be redone and assistance in resolving the issue. For future vendor errors, the County will review its vendor agreements, and, where appropriate, seek compensation for costs associated with rectifying errors.
To make certain that its staff learn of election-related errors and identify trends in error types, and to allow Santa Clara to identify necessary modifications to processes that will reduce or eliminate such errors, Santa Clara should immediately formalize a policy requiring the continued use of a spreadsheet similar to the one created to track election-related errors.
County of Santa Clara Response to Recommendation #5
The County of Santa Clara agrees with the recommendation to formalize a policy requiring the use of an error tracking spreadsheet to support staff learning and awareness, identify trends in error types, identify necessary process modifications, and reinforce adherence to error prevention processes.
To ensure accuracy and consistency in the creation, review, and distribution of election-related materials, Santa Clara should review and document in detail all policies and procedures by October 2018, prioritizing its documentation for the divisions that are responsible for the most frequent and egregious election-related errors. Specifically, Santa Clara should review and formalize Mapping’s policies and procedures by January 2018, to allow time for implementation before the June primary election process. By October 2018, Santa Clara should review and formalize policies and procedures for the remaining divisions—including the Ballot Layout, Candidate Services, and Vote by Mail divisions—to provide adequate time for implementation before the November general election process.
County of Santa Clara Response to Recommendation #6
The County of Santa Clara agrees with this recommendation and is currently reviewing the policies and procedures for these divisions. While the Registrar’s Office has hundreds of written procedures, checklists, manuals, and other job aids for its staff members and election volunteers, the department acknowledges that many of its procedures need to be documented or need to be more detailed. The recommendation to review and document all policies and procedures regarding voting information error prevention is valid, and the County anticipates numerous benefits of new and more detailed documentation and procedures.
To reduce the risk of staff errors, inconsistencies in procedures, and the loss of institutional knowledge in the creation, review, and distribution of election related materials, Santa Clara should develop and implement training for its staff that includes instruction on its comprehensive policies and procedures. The development of this training should take place concurrently with Santa Clara’s detailed documentation of its policies and procedures, and Santa Clara should require relevant staff to attend this training before each major election.
County of Santa Clara Response to Recommendation #7
The County of Santa Clara agrees with the recommendation that having more formalized training, supported by new and more detailed documentation, policies, and procedures, will greatly assist managers and supervisors in providing staff members a consistent instructional training experience.
To ensure the accuracy of election-related materials, Santa Clara should immediately implement a procedure for candidates, voting districts, or others who submit documents to have them verify the accuracy of the electronic versions of those documents once Santa Clara has formatted them.
County of Santa Clara Response to Recommendation #8
The County agrees that the recommendation of developing a procedure that would include verifying the accuracy of electronic versions would improve the overall data integrity process, and after evaluating alternatives, the Registrar’s Office will attempt to implement within the recommended time frame. The County currently sends City Clerks election-related materials before going to press, for their review and sign-off, and will develop a method to extend such a verification step to all other candidates and voting districts.
To ensure consistency in responding to election-related errors, Santa Clara should immediately implement a contingency plan or decision matrix that includes specific guidelines for the actions it will take based on the number of voters affected and the significance of the errors. In instances in which it chooses to deviate from this plan, Santa Clara should document its reasons for deciding to do so.
County of Santa Clara Response to Recommendation #9
The County of Santa Clara agrees with the recommendation of implementing a written decision matrix to improve the consistency of future responses to errors. Although the County believes that, in recent years, the Registrar’s Office has made strides in responding more comprehensively and with greater transparency when voting information errors have occurred, having a written decision tool would facilitate the ability of the Registrar’s Office to expeditiously determine the appropriate responsive actions and ways in which voters will be notified, and to ensure consistency in the future.
To maintain the public’s confidence in it and its functions, Santa Clara should immediately include in its postelection reports descriptions of any election-related errors, accounts of why the errors occurred, and explanations of how it plans to prevent the errors from occurring in the future.
County of Santa Clara Response to Recommendation #10
The County of Santa Clara agrees with the recommendation to include in its post-election reports descriptions, reasons, and ensuing prevention plans with respect to future election-related errors. The reports will benefit from the increased transparency that the disclosure of election-related errors and prevention plans will provide.
We would like to thank the California State Auditor for the thoughtful work on this report. If you have any questions, please do not hesitate to contact me via phone at (408) 299-5828 or via email at firstname.lastname@example.org.
John P. Mills
Deputy County Executive
CALIFORNIA STATE AUDITOR’S COMMENTS ON THE RESPONSE FROM
THE COUNTY OF SANTA CLARA
To provide clarity and perspective, we are commenting on the response to our audit report from the County of Santa Clara (Santa Clara). The numbers below correspond to the numbers we placed in the margin of Santa Clara’s response.
Consistent with our standard practice, we only share the portions of the draft report and recommendations that pertain to the responding agency. Thus, we did not share with Santa Clara the portions of the draft report that related to the Secretary of State.here. For example, here we explain that although the Mapping Division has a procedures manual that it created in 2013, the document is still in draft form, and it provides only general instructions to staff on how to enter voting district boundaries into Santa Clara’s mapping software. In another example on the same page, we indicate that Santa Clara’s documents related to proofreading election-related materials lack specificity about how staff should conduct this proofreading. We also state here that we expected to find centralized and detailed instructions for staff to follow when completing the various proofreading steps; however, these instructions were limited and were not centralized in a single location, such as in a procedures manual. Finally, here, Santa Clara’s registrar acknowledged that Santa Clara continues to work to formalize its policies and procedures, and she explained that they have been a work in progress for several years because of competing priorities. Nevertheless, we are pleased to learn from Santa Clara’s response that it agrees with our recommendation, which includes reviewing and documenting in detail all policies and procedures by October 2018.
California Secretary of State
October 2, 2017
Elaine M. Howle, CPA
California State Auditor
621 Capitol Mall, Suite 1200
Sacramento, CA 95814
Re: Response to Draft Audit of Santa Clara County Registrar of Voters
Dear Ms. Howle:
Thank you for the opportunity to respond to your recommendations related to the Secretary of State’s office, which are included in your draft audit report of the Santa Clara County Registrar of Voters’ review and distribution of election-related materials.
As the chief elections officer of the State of California, I take seriously my responsibility to ensure that elections are efficiently conducted and that state election laws are enforced. My office is committed to assisting counties in order to ensure accurate and timely information is provided to voters and I look forward to the opportunity to improve that assistance.
As Secretary of State, I have witnessed first-hand the steadfast hard work and dedication of our elections officials in each and every county, even when faced with consistently limited resources. I look forward to reading your entire report in order to gain perspective on how particular issues identified in Santa Clara may be mitigated or avoided in the future throughout the state. Further, I am committed to exploring how my office might address your specific recommendations, including an analysis of whether the recommendations require additional staff resources to ensure adequate implementation.
I appreciate your staff’s professionalism throughout this audit, as well as your identification of opportunities for improvements my office may be able to implement related to the creation and distribution of election-related materials by county elections officials.
Should you have any additional questions, please contact Jana Lean, Chief of Elections at (916) 653-5144.
Secretary of State