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Independent audit report on the performance of the duties and functions of election officials – 42nd General Election

4. Findings – Major and other

Our audit findings and conclusions are presented on an aggregate level. Our results are not attributed to any specific ED, polling site, polling station or election official. Our key findings and other observations are described below. Our recommendations are included in Appendix A to this report.

4.1 Performance of the duties and functions of election officials

A Canadian citizen who is at least 18 years of age on election day may vote in the ED in which they reside. The CEA provides procedural safeguards designed to protect the integrity of the electoral process, one of which requires electors to prove eligibility (identity and residence) before receiving a ballot. For most electors who are already registered at their current address and therefore included on the List of Electors, election day procedures involve a simple, efficient check of one or more pieces of acceptable identification to confirm identity and address of residence. Based on the sample tested, approximately 90% of electors voted in this manner in the 42nd General Election. The remaining 10% of electors required special administrative procedures prior to being issued a ballot and exercising their right to vote.

The following table outlines circumstances that require special procedures as well as the approximate percentage of electors (making up the 10% referred to above). Note PwC did not observe execution of any transfer certificates in our testing.

Special circumstances Percentage of electors (Approximate)
An elector is not on the List of Electors for their polling division (registration certificate). 6.0 %
An elector requires a minor correction to their electoral information on the List of Electors (correction certificate). 2.0 %
An elector is previously crossed off as voted on the List of Electors (correction certificate). 0.5 %
An elector does not have identification with their address; requires an attestor to provide proof of the elector's residence (oath of residence certificate). 1.0 %
An elector's qualification or residence is challenged (oath of qualification). 0.5 %
An elector is voting by transfer certificate (transfer certificate). N/A
Total 10.0 %

4.2 Major findings

4.2.1 No major findings resulting from deviations in key controls and procedures for regular electors.

Our testing did not identify any major findings from deviations in key controls and procedures for regular electors (i.e. the approximately 90% of electors). In addition, we only noted the one following major finding from a deviation related to a key control for special procedures (i.e. where those electors requiring special procedures make up approximately 10% of electors). Details of this finding are outlined in the section below.

4.2.2 Oaths/declarations are not always administered or signatures obtained for electors requiring special procedures.

Depending on the circumstances, special procedures may include administering a verbal oath to the elector, administering an oral warning to an elector and their attestor, and/or administering written oaths/declarations to the elector and/or attestor. These procedures are intended to reinforce the integrity of the electoral process by ensuring that ballots are only issued once to eligible electors.

In several of the special procedures that are administered, specifically the registration certificate, the correction certificate (in the case where the elector's name is already crossed off the List of Electors in error) and the oath of residence, a written oath/declaration is required to be read and signed by the elector/attestor in acknowledgement. The following outlines the nature of the oath/declaration required under each of the primary special circumstances.

During the observation of the administration of these oaths/declarations by the DRO, our audit noted circumstances beyond our reporting threshold where the DRO did not request the signature of the elector on the applicable certificate. As a result, the certificate did not include evidence that the elector had read and signed the applicable oath/declaration. We also noted circumstances where the DRO did not read aloud the oral warning to the elector and attestor when an oath of residence certificate was administered. In addition to our observation at advance polls and ordinary polls, we also examined election documents at EC's warehouse facility. Many of the certificates examined did not provide evidence that the applicable oath/declaration was administered (i.e. elector/attestor signatures in place for written oaths/declarations and appropriate notations for confirmation of verbal oaths administered).

If the DRO does not obtain the elector's signature or does not indicate the elector's affirmation on the applicable certificate, there is no evidence that the elector has confirmed they are qualified to vote, have not requested a ballot in the electoral event or that they reside in the electoral district. In the case of an attestor, without evidence of the administration of the written oath through the attestor's signature, there is no confirmation that they meet the criteria to attest for the elector.

4.3 Other observations

The following represent observations noted from the audit that were record-keeping in nature (secondary controls).

4.3.1 When initiating registration certificates, it was not evident how REGOs verified the elector's place of residence to ensure they were directed to the correct polling station.

An elector whose name is not on the List of Electors for their polling division may register in person at advance polls or at general election day polls. In the case where the elector needs to be registered, the REGO has to be satisfied that the address of the elector is within the appropriate polling division. REGOs are expected to obtain the elector's address and, where necessary, compare it to the poll key to confirm that the elector's residence is within the ED and a polling division being served by that polling site. The poll key is a list of addresses and corresponding polling stations within an ED.

For electors served at the registration desk, we identified instances above our reporting threshold for a secondary control when the REGO did not review the poll key to confirm that the elector's address fell within the polling divisions served by that polling site. We appreciate that an elector's address could have been familiar to the REGO and, therefore, no further verification was considered necessary. However, given recent changes to boundaries across and within EDs, if the poll key is not consulted, there is a risk that an elector could vote at the wrong polling division or potentially in the wrong ED.

4.3.2 In an effort to serve the elector and minimize wait time, PCs did not consistently mark electors as having voted as soon as their ballot was cast, as prescribed by the Act.

Separate controls are in place to confirm that the elector has only been issued one ballot for that electoral event (i.e. striking off the List of Electors by the DRO) and that the ballot has been returned and placed in the ballot box (checking off the elector as voted on the associated documentation by the PC).

Section 162 of the CEA stipulates that the PC must indicate that the elector has voted. This allows for effective reconciliation of the ballots. This is typically evidenced by a check mark in the box next to the name of the elector on the List of Electors or the record of votes cast at advance polls. If an elector is not on the List of Electors, the PC is required to tick the elector as having voted in the poll book (or on the record of votes cast at advance polls). The CEA prescribes that this duty must be performed as soon as the elector's ballot has been deposited in the ballot box. This duty is in addition to having to cross off the elector's name when the elector appears on the List of Electors.

Our audit identified instances, above our reporting threshold for a secondary control, where the PC did not mark the elector as voted as soon as the elector's ballot was deposited in the ballot box. In some cases, the PC marked the elector as having voted at the time they presented the required ID but prior to the elector being issued a ballot; while in other circumstances, the PC checked off the elector as voted after the elector had left the polling site. In some cases, this activity was completed in batches, specifically at advance polls. Further to our examination of election documents at EC's warehouse facility, we noted that in most cases, electors were eventually checked off as voted.

If electors are marked off as voted prior to ballots being issued or well after an elector has left the polling site, the lack of real time monitoring results in the inability to confirm whether the elector did in fact cast their ballot. This may also cause difficulties for election officials when they reconcile the number of electors who voted to the number of ballots.

4.3.3 Overall, election officials were challenged when conducting special procedures due to lack of familiarity of when and how to complete the various forms and the low volume of special electors at any one polling station. As a result, certificates, forms and checklists for special procedures were not always correctly or completely documented.


As noted above, the administration of special procedures requires the initiation of a certificate based on the nature of the situation. The sections of the individual certificates require information pertinent to the situation but typically require the name and address of the elector and any other relevant information, the information related to the oath/declaration to be administered, a signature of the elector and attestor, as applicable, and the signature and date by the DRO. Detailed testing results identified situations, above our reporting threshold for secondary controls, where the wrong certificate was used for the special procedure being faced, e.g. correction certificates used for registrations. Further, testing results confirmed a number of certificates were either incomplete or completed inaccurately as compared to the information required (i.e. both sections 2 and 3 of the correction certificate were completed; fields of the registration certificate not completed).

Poll book

When special procedures are administered at ordinary polls, the duties of the PC include having to record the proceedings in the appropriate section of the poll book. The poll book should have an entry for each elector that required special procedures and the information in the poll book must agree to the information on the corresponding certificate. Our audit noted examples above our reporting threshold where the poll book was not completed accurately and completely for the administration of the special procedures observed. Inaccurate or incomplete entries in the poll book do not provide visibility of the details of the interaction with the elector and the special procedures administered. As a result of our examination of election documents at EC's warehouse facility, we noted instances where a certificate did not have always have a corresponding entry in the poll book.

4.4 Assessment of administrative controls established by EC

As outlined in our approach section, the assessment of the administrative controls was based on results of our detailed review of the training program materials and guidebooks, observation of the delivery of selected training sessions and interviews, and enquiries with EC staff and election officials, including DROs, PCs, REGOs, training officers and recruitment officers.

Overall, feedback was positive on the content of the training programs and the format of how the training was delivered. Further, election officials found the availability of the guidebooks and other aids very useful in assuming their responsibilities and troubleshooting when they were unsure of how to proceed. Feedback was, further, very positive on the role of the central poll supervisor in consistently providing ongoing support and conducting quality checks periodically to avoid delays later in the day when needing to reconcile records and ballots. Opportunities were identified, however, to focus more time on the administration of the special procedures and the associated documentation as election officials did not feel fully equipped to deal with these scenarios after completing their in-class training program. The following represent our findings related to the design and implementation of the training program and associated tools.

4.4.1 Opportunities were noted to enhance the training program to better equip election officials to perform their duties.

In order to equip the approximately 285,000 temporary workforce hired to successfully administer the voting process during the general election, a formal training program is in place and delivered to each election official in advance of taking on their responsibilities. This is no small task; once the writ is dropped, the RO has the task of finding people who are qualified and available for the election period to fill key support functions – including the recruitment officer and training officers in supporting them in seeking out/screening potential candidates, training, assessing and swearing them in, and supporting them in the completion of their assigned functions during the advance polls and ordinary polls.

Depending on the size of the ED, a RO/recruitment officer needs to find a workforce of approximately 770Footnote 6 individuals to work at advance and ordinary polls, which includes a redundancy factor to allow flexibility for those who drop out in advance or do not show on the day of voting. Format of the training program

The content and format for the training program was redesigned for the 42nd General Election, focusing on learning techniques appropriate for adult learners, which included the support of videos to demonstrate scenarios that could be faced at the polling site and to supplement the information being delivered by the training officer. In addition, the training program materials were designed to ensure consistency in training delivery: a standard slide deck to be used by training officers with mandatory speaking notes in the delivery of the training, a training guide for training officers and pre-established exercises for participants to complete.

The training program for the 42nd General Election was designed so that there was a tailored training curriculum depending on the intended role at the polls and whether the duties would be performed at advance or ordinary polls. The various in-class training courses delivered within each ED by the training officer(s) included:

In order to ensure that all election officials are provided the training required (based on their expected role), training officers within each ED typically deliver approximately 33Footnote 7 in-person training courses in the weeks leading up to the advance and ordinary poll days. A 3-hour course with limited to no breaks was provided to get through all the materials required to equip the election officials with sufficient knowledge to assume their assigned duties. As per the design of the training program, training officers used a combination of visual aids (videos and posters), slide decks, the guidebooks and the actual templates/tools used at the polls to instruct participants.

Although it is widely accepted that the most effective delivery of training is in-person, inherent challenges exist with the delivery of in-class training to a temporary workforce, across a vast geography, in two official languages and in a very short time period.

Results of interviews with a sample of training officers from the 42nd General Election confirmed the challenge with delivering a significant amount of technical information in a limited timeframe. EC has determined that training may not exceed 3 hours due to practical constraints around trainee availability. A 3-hour course with limited to no breaks was necessary to get through all the materials required to equip the election officials with an understanding of how to perform their duties; however, specifically in the case of the DRO/PC training sessions, even this amount of time was insufficient, as not all topics were able to be covered in sufficient detail and many individuals were tired/weary by the end of the training course, impacting participants' ability to absorb all the material being presented.

Without sufficient preparation in advance of the poll days, election officials were often uncomfortable with their duties at the outset of their assigned poll days and could not "hit the ground running" in an efficient and effective manner relative to the administration of special procedures.

It should be noted that the completion of practice scenarios was the only opportunity for the training officer to observe participants working through the examples and to try to identify any participant who might not be qualified to take on the duties and responsibilities of an election official and should not proceed to the next step (i.e. swearing in and confirmation of responsibilities for advance or ordinary poll days). Due to the amount of guidance that participants needed during the completion of the practice scenarios from the training officer, in some scenarios, limited opportunity was available to the training officer to assess the competence of the participants. Training curriculum

The training curriculum generally followed a consistent flow for each of the intended audiences, and covered the following topics.

The first few topics were general to all election officials and provided the necessary background material assuming limited exposure to the electoral process. The topics covered in these areas relied on videos to deliver key messages. The information provided allowed all participants to have a baseline understanding of the electoral process and expectations for polling days. This coverage of these background topics used up approximately 60Footnote 8 minutes of the 180 minutes of the individual training courses. Because this background material was covered consistently for all training audiences, the central poll supervisors were exposed to the same material three times as they were expected to attend training for all audiences to ensure they understood the responsibilities and activities of the other election officials.

Beyond the background topics, the remainder of the training courses focused on the specific duties and functions of the individual audiences.

DRO/PC training

The details of the roles/responsibilities of the DRO/PC included several key components such as: introduction to acceptable forms of identification for electors to prove their names and residence; serving electors and the potential special procedures that will be required; and counting/reconciling ballots. Based on the feedback from the majority of DROs and PCs interviewed and consistent with the results of the audit observations outlined above, the most complex component of the responsibilities at the polling station is the completion of the certificates, poll book and the administration of the oaths/declarations.

Given the amount of background content that had to be included in the in-class training, although the voting scenarios, the certificates, the poll book and the associated oaths/declarations were covered, limited time was able to be spent in-class to sufficiently cover the different scenarios. Topics requiring coverage included the details of each certificate (including the fact that the correction certificate was actually used for two different purposes and as a result, only certain sections of the form would be applicable depending on the scenario), the corresponding entry in the poll book and the administration of the associated verbal or written oath/declaration.

In addition, while practice scenarios/examples were included in the course materials, limited time was available to allow participants to work through all the different scenarios in sufficient time and then allowing a group take-up, recap of the scenarios to allow individuals to ask questions and confirm their understanding. The practice examples were the last step of the training course material and it was challenging for participants to successfully work through the examples given the timeframe to complete the exercises and the amount of material they had been exposed to in the previous three hours.

Under pressure of long line-ups at the polling station, frustrated electors and long days, DROs and PCs often did not feel well-equipped to quickly and efficiently identify which circumstances required which certificate, to easily navigate through the completion of a certificate, to complete the associated entry in the poll book and the administration of the oaths/declarations. Ultimately, this led to the observed results of incomplete/inaccurate certificates and entries in the poll book, the improper administration of the associated oaths/declarations and general discomfort with the voting scenarios and the appropriate completion of the associated administrative steps.

REGO training

For the REGOs, feedback was similar to that of the DRO and PC. Overall, feedback was positive on the ability to cover the material to a sufficient level in the 3-hour allotted timeframe, given that the responsibilities of the REGO and information officers are fewer and less complex that those of DRO and PC. However, given that the REGO is responsible for identifying the voting scenario and initiating the appropriate certificate in an effort to streamline the process, feedback from REGOs demonstrated that they would have benefitted from more practice examples and role playing related to the different scenarios, the certificates and the other tools required to be used. Tools and guidance

As part of the delivery of the training program, participants were provided with guidebooks to use as a reference when serving electors. In addition, the role of central poll supervisor exists to provide support and guidance to election officials when serving electors. As part of their duties, the central poll supervisor has been encouraged to conduct regular touch points with election officials responsible for greeting, registering and serving electors to address and resolve any questions or concerns in relation to the discharge of their responsibilities. In addition, expectations were set with the central poll supervisor to periodically conduct quality checks related to the documentation being completed by the election officials to identify and resolve any issues in a timely manner.

As noted above, given the amount of background content that had to be included in the in-class training, although the voting scenarios, the certificates, the poll book and the associated oaths were covered in training, insufficient time was able to be spent in-class to sufficiently cover these topics. Accordingly, the guidebooks were a useful resource for election officials in preparation for and on advance and ordinary poll days. Feedback from DROs, PCs and REGOs confirmed the usefulness of the guidebooks as a quick reference (if time permitted) if they were unsure of how to proceed. Some individuals took the opportunity to highlight the guidebooks, including the organization and index of the guidebooks to facilitate efficient navigation through the topics. General feedback from the election officials confirmed that the central poll supervisor was available as a support in case there were questions about a specific voting scenario or how to complete the associated documentation. These support tools and functions mitigated, to some extent, the risk of inappropriate administration of the different voting scenarios.

Footnote 6 As per Elections Canada.

Footnote 7 As per Elections Canada.

Footnote 8 As per Elections Canada.