Report 2017-107 Recommendation 6 Responses

Report 2017-107: 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 (Release Date: October 2017)

Recommendation #6 To: Santa Clara County Registrar of Voters

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 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 Ballot Layout, Candidate Services, and Vote by Mail--to provide adequate time for implementation before the November general election process.

Annual Follow-Up Agency Response From October 2020

Progress from the last report includes the expansion of the Ballot Layout Division's (BLD) operations with the creation of official ballots in nine languages for the first Voters' Choice Act election, the March Presidential Primary Election, along with four new language-specific Election Specialists; as well as five new languages requiring the creation of facsimile ballots for the November Presidential General Election. BLD has been able to fine tune several of their procedures, such as the Candidate Statement Proofreading Checklist; Election Preparation and Setup Overview; Measure Document Proofreading Checklist; Proofreading CVIG Instructional Filler Pages-Updated; Proofreading Division Request-Updated; Proofreading English Candidate Statements; Proofreading Official Optical Scan Ballot; Standards and Style Guide-Updated; and How to Proof the Office Data Detail Proof List Report OIMR005.

We prioritized the four divisions of Mapping, Candidate Services, Ballot Layout, and Vote-by-Mail to meet this reporting deadline. Cumulative submissions and several procedures currently in progress represent a significant portion of the review and documentation of procedures required to fulfill the audit recommendation. Due to new legislation, as well as the new voting model and new voting equipment, it is essential that existing procedures be updated on a continuous basis. We believe our progress to date satisfies this recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: Fully Implemented

Annual Follow-Up Agency Response From October 2019

GIS Mapping: Access the Planning and Development Department Server, Creating GIS District Boundary Data, Generating Drayage Route Report Assignments, Generating E-Night Courier Assignments, Introduction to the ROV Online Precinct Map Viewer, Uploading a GIS Precinct Map into the Online Election Night Reporting Module, Uploading a Precinct PDF File Through the County's Content Management Application Website, and Verifying a City Annexation procedures.

For Candidate Services: City Clerk and District Administrator Meetings, Official Candidate List, Random Alpha Drawing, Receiving Measure Resolutions, and Withdrawal of Candidacy procedures.

The Ballot Layout procedures consist of Proofreading Candidate Statements, Proofreading Covers, Proofreading Labels, Proofreading Official Optical Scan Ballots, and JAWS screen reader Program materials of which training PowerPoints have also been created for each of these processes.

The Vote-by-Mail procedures include E+3 Postmark, Write-In Tally, procedures with training materials and PowerPoints. Supporting documentation has been uploaded.

A centralized location for all procedures for each division has been created. We prioritized the four divisions (Mapping, Candidate Services, Ballot Layout, and Vote-by-Mail)in an effort to meet this reporting deadline. Cumulative submissions submitted, as well as a number of procedures currently in progress represent a significant portion of the procedures for recommendation. Due to new legislation, as well as new voting model and new voting equipment, it is understood that many of our existing procedures will need to be updated, therefore preparation of new policies and procedures will be constant; we believe that our progress to date represents that we have met this recommendation.

California State Auditor's Assessment of Annual Follow-Up Status: Partially Implemented

We commend Santa Clara in its efforts to implement this recommendation, and we recognize that it has established detailed policies and procedures for most of its divisions. We will continue to report this recommendation as partially implemented until Santa Clara finalizes its policies and procedures for its Ballot Layout Division.

1-Year Agency Response

Progress from the last report includes the formalized process of creating policies and procedures for all divisions prioritizing the Ballot Layout, Candidate Services, Mapping, and Vote-by-Mail divisions. Numerous draft documents have been created for each of the named divisions and tested during both the June 2018 and set up of the November 2018 elections. As multiple offices are involved with the review and approval of each of these documents, it is anticipated that this process will continue to take further time for full development and implementation; therefore, this recommendation is not yet completed. A few of the completed procedures are attached as evidence of supporting documentation and have been uploaded separately.

California State Auditor's Assessment of 1-Year Status: Pending

6-Month Agency Response

Progress from the last report includes continued efforts to document all policies and procedures in time for implementation before the June 2018 primary election process. For the record, several key positions within the Registrar's Office have changed since the December 2017 report. The vacant Management Analyst position of the Policies & Procedures Division has been filled as of late March. And, also for that division, the recruitment for the vacant Associate Management Analyst is on-going. This division is responsible for the creation and implementation of the Department's Policies and Procedures. The Election Division Coordinators for both the Ballot Layout Division (BLD) and the Candidate Services Division (CSD) have both retired effective end of 2017. The Election Process Supervisor was promoted to Coordinator in BLD and now have several new personnel within BLD. In CSD, the recruitment to fill this vacancy is on-going at this time. The office has also hired three Management Aide positions to help write up the documentation of training, policies, and procedures while working with each of the specific division managers. We have begun to formalize policies and procedures for all of our divisions prioritizing the Ballot Layout, Candidate Services, Mapping and Vote-by-Mail divisions. Numerous draft documents have been created for each of the named divisions and tested during the nomination filing and ballot layout periods of the June 2018 Election. Those documents are currently under review at this time. It is anticipated that approved final policies and procedures will be produced at the next report back in October 2018.

California State Auditor's Assessment of 6-Month Status: Pending

60-Day Agency Response

Originally responded 12.22.17. In accordance with the recommended implementation time frame of January 2018, we have reviewed and formalized a policy and numerous procedures for the Mapping Division. We have begun reviewing and formalizing policies and procedures for the Ballot Layout, Candidate Services, and Vote-by-Mail divisions targeting completion by October 2018, in order to meet the recommended implementation timeframe and provide adequate time for implementation before the November 2018 General Election. To the extent possible, the intention is to centralize all procedures for each division into a unified procedure manual for each division. We have prioritized the Mapping Division Procedure Manual first in order to meet the January 2018 recommended implementation time frame, and implement Recommendation #1's procedure to request each voting district certify that its boundaries are accurate through receiving and verifying the accuracy of the current map on file with the Registrar of Voters. In addition, on December 15, 2017, we implemented "ROV Policy - Requesting Proof from Printing Services or Vendor_Implemented 121517" in order to address a concern in the State Audit report #2017-107 that we had not documented our practice of verifying the accuracy of voter data in print or mailing jobs. This policy, a new policy for the Mapping Division to implement the procedure to request each voting district certify its boundaries, and the Mapping Division Procedure Manual as of December 22, 2017, have been attached separately as Supporting Documentation.

California State Auditor's Assessment of 60-Day Status: Pending

All Recommendations in 2017-107

Agency responses received are posted verbatim.