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Independent audit report on the performance of the duties and functions of Election Officers – By-elections February 25, 2019

Executive summary

In response to section 164.1 of the Canada Elections Act, PricewaterhouseCoopers (PwC) was engaged to perform an independent, statutory audit and report on whether deputy returning officers (DRO), poll clerks (PC) and registration officers (REGO) have, on all days of advance polling and on polling day, properly exercised the powers conferred on them, and properly performed the duties and functions imposed on them, under sections 143 to 149, 161 to 162 and 169 (hereinafter referred to as “the relevant sections”) of the Canada Elections Act (CEA or “the Act”) for each general election and by-election. This report is in relation to the by-elections held in the Electoral Districts of Burnaby South (British Columbia), Outremont (Quebec) and York—Simcoe (Ontario) on February 25, 2019 (hereinafter referred to as “the Electoral Districts” or “EDs”).

In addition to other roles required to prepare for and support advance polling and election day, each returning officer (RO) is responsible for appointing a DRO, a PC and a REGO (collectively referred to as “election officers”) to perform election related duties at a polling site. One DRO and one PC are required per polling station and typically, one REGO is assigned to each central polling site/place. It is the duties of these specific election officers that are included in the scope of this audit under S.164.1 of the Act.

The scope of the duties of election officers as prescribed in the relevant sections of the Act require election officers to register electors, request and examine each elector’s proof of identity and address as well as administer and complete prescribed forms and certificates on all days of advance polling (held February 15 to February 18, 2019) and on election day (held on February 25, 2019) in relation to these by-elections.

Any 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 residency) 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 our testing results, approximately 94% of electors voted in this manner. The remaining 6% of electors tested required special administrative procedures prior to being issued a ballot.

Election officers must administer special procedures for all electors whose residence is going to be attested to, who are not on the List of Electors, whose name has been previously crossed off the List of Electors in error or who require minor corrections to their information. Depending on the circumstances, special procedures include initiating the appropriate certificate or form, administering a verbal or written oath/declaration to the elector and administering a verbal warning/written oath to an elector and their attestor. These procedures are intended to reinforce the integrity of the electoral process by ensuring that ballots are only issued once to eligible electors.

Our audit findings and conclusions are presented at an aggregate level. Our results are not attributed to any specific ED, polling site, polling station, or election officer. While we did not identify any major findings, our audit did note other observations, which are described below. We are not proposing any new recommendations as a result of the February 25, 2019 by-elections.

We performed our audit in accordance with the Canadian Standard on Assurance Engagements 3001: Direct Engagements (CSAE 3001).

Audit criteria

For this audit, the principal criteria and therefore our audit mandate are specifically prescribed in the relevant sections of the Act described above. For the purpose of this audit, a significant deviation in the exercise of powers and the performance of the duties and functions of election officers was based on two levels of controls and procedures as well as reporting thresholds. Key controls and procedures are those performed by election officers which establish a person’s qualification and entitlement to vote. Secondary controls are those which support/reinforce the elector’s established qualification/entitlement to vote and are typically more record-keeping in nature. Our audit criteria for this audit are consistent with our audit criteria reported on in our independent audit report on the performance of the duties and functions of election officers dated February 16, 2016 in relation to the 2015 general election and our subsequent reports in relation to the federal by-elections that have taken place since 2016.

The establishment of thresholds for reporting purposes was critical during the planning of the audit. The reporting thresholds were agreed with management and reflect the relative importance of the control. For key controls, a deviation of 5% or more was considered a major finding. For those same key controls, a deviation of 2%–4.9% was considered as other observations. For secondary controls, a deviation of 11% or more was considered as other observations. The reporting thresholds are consistent with our report on the 2015 general election and our reports on by-elections held since 2016.


In order to provide reasonable assurance as to whether election officers performed their duties and functions as prescribed by the CEA, we selected a sample of polling sites in the EDs and gathered sufficient and appropriate evidence to conclude on the audit objective. Evidence gathering techniques comprised of direct observation, enquiries and inspection of election documents (representing the certificates, forms, reports and other paperwork required to serve an elector and document the results).

In order to assess whether DROs, PCs and REGOs properly performed the duties imposed on them under the relevant sections of the Act, we determined that it was necessary to perform audit procedures on site at polling sites and stations at advance polls (February 15 to 18, 2019) and on election day (February 25, 2019). For these by-elections, the ED of York—Simcoe was comprised of a combination of rural and urban polling sites while those of Burnaby South and Outremont were only comprised of urban polling sites according to EC’s designation of polling divisions/sites. We selected a sample of urban sites in Burnaby South and Outremont and urban and rural polling sites in York—Simcoe. This resulted in PwC auditing 216 electoral interactions.

There were no significant changes to administrative controls such as training material (e.g. guidebooks) for these by-elections since the last federal by-election held on December 3, 2018. Accordingly, we relied on our assessment of administrative controls in relation to the audits we conducted for the 42nd general election and subsequent by-elections as a basis for forming our conclusion. Overall, EC’s training program is comprehensive and effective for providing prescriptive guidance and support to the temporary workforce that was hired to work at the by-election.

Summary of findings

We concluded that:

On all days of advance polling and on election day, election officers properly exercised the powers conferred on them, and properly performed the duties and functions imposed on them under the relevant sections of the Act with respect to regular electors and electors requiring special procedures. Overall, no major findings were identified during our audit. While there were some inconsistencies in the completeness of the documentation, overall these errors were not pervasive and were therefore considered “other observations”.

EC asked us to report any other relevant observations that we captured during the course of our work that might assist them to improve or enhance their processes. In this context, we did not identify additional notable observations other than those already noted in our reports on the 2015 general election and the by-elections that have taken place since 2016.