International Foundation for Electoral Systems game out these types of risks and make sure this is part of the information and communications technology (ICT) system protocol so that supervisors automatically get warnings should these types of cases emerge. IT personnel may also require particular protection from political influence or interference, compounded by the fact that qualified IT personnel may be difficult to recruit and retain, as discussed above. Failures of trust, such as perceived inflation or deflation of voter lists, persist around the world. Apart from procedural aspects plaguing the accuracy of voter lists, which are categorized herein as procedural exposure, the electorate may perceive that voter data is not held securely. For example, there might be rumors that the government is printing fake ID cards to impersonate voters (these voters may be deceased or residing abroad but still listed on the voter rolls). It is difficult to prove such claims without conducting a comprehensive audit, but the shadow of doubt may very negatively impact the process. Finally, the collection and processing of election returns is now semi- or fully automated for EMBs that use “contained” results management systems. The associated processes may also be burdened by political considerations. For example, given a choice, EMBs would typically err on the side of protecting the perceived integrity of election results rather than providing maximum transparency. They may decide to publish only the summary results and not the full breakdown of results by polling stations. One example of a practice increasing the transparency of and trust in a system, without compromising security, is in South Korea. Voters mark physical ballots, which are sealed and transported to a constituency counting center. There, in front of political party observers, ballots are scanned and counted using optical scan voting systems. Teams feed ballots into the machines, which then emit stacks of 100 votes for the same party. These stacks are run through the machine again to be counted, and observers are present for both processes.95 d) Legal Exposure It is important for primary election legislation to contain provisions enshrining principles governing the creation, use, processing, and publication of data in elections, without being so prescriptive or opaque that they create challenges in implementation. Without a clear and implementable legal framework, the EMB may face legal exposure either in terms of potential lawsuits against different parts of the electoral process, or with respect to legal restrictions that make the procurement or use of election technology difficult in practice. For example, the law may be so prescriptive that it requires an EMB to procure and deploy specific technology platforms within unrealistic deadlines, and this may set the EMB up to fail well before the election is initiated. Or, as in the case of Kenya, the EMB may be required by law to submit regulations governing election technology for parliamentary approval, which opens these rules up to modification by political actors who do not have any practical technical knowledge.96 95 Tim Meisburger, “Korean Elections: A Model of Best Practice,” The Asia Foundation, 2016, https://asiafoundation.org/2016/04/20/korean-elections-a-model-of-best-practice/. 96 Section 44 (5) and section 109 of the Kenya Elections Act, 2011. 24