International Foundation for Electoral Systems transparency and accountability of the process, as well as integrity and verifiability of election results. On the other hand, as societies evolve and technologies advance, international institutions are continually updating and refining standards for cybersecurity, transparency, open data, and privacy. These evolving standards stem from – and must adhere to – fundamental political rights established by the Universal Declaration of Human Rights (UDHR) and the International Covenant on Civil and Political Rights (ICCPR).8 Beyond these universal instruments, international organizations and governing bodies are increasingly establishing international standards on the conduct of elections in which any election-related data is stored digitally. Although not the first forum to establish guidelines on data management, recognized international standards are summarized in the United Nations (UN) General Assembly Guidelines for the Regulation of Computerized Data Files.9 Adopted by the General Assembly in 1990, these guidelines provide broad principles of data management that place responsibility for data on those persons who collect it, specifically requiring that data collectors be responsible for ensuring that the data is accurate, transparently and lawfully collected, properly restricted to avoid discrimination, securely stored, and lawfully disseminated.10 The UN guidelines do not provide specific technical requirements to ensure that these principles are met, and the guidelines apply only to “governmental international organizations.”11 These guidelines define the principle of security as taking appropriate action to “protect the files against natural dangers, such as accidental loss or destruction and human dangers, such as unauthorized access, fraudulent misuse of data or contamination by computer viruses.”12 Though the guidelines do not explicitly mention election technology, they have implications for electronic data management in electoral processes and outline protections that should apply to the full range of stakeholders involved in the electoral process – voters, candidates, election officials, among others – whose data may be collected. There are additional standards for the introduction of technology in voting or vote-counting processes specifically. Most notably, the Council of Europe’s 2017 e-voting standards place specific responsibility on EMBs for the “availability, reliability, usability and security of the e-voting system.”13 The Council of Europe also maintains a set of non-binding standards for e-voting that cover the application of general principles, such as universal suffrage and accountability, to e-voting technology. Universal suffrage requires that voting interfaces are easy to use and understand for all voters, for example, and 8 Article 21 of the UDHR states that the will of the people “shall be expressed in periodic and genuine elections which shall be by universal and equal suffrage and shall be held by secret vote or be equivalent free voting procedures.” 9 UN General Assembly, Guidelines for the Regulation of Computerized Data Files, December 14, 1990, res. 45/95. http://www.refworld.org/pdfid/3ddcafaac.pdf. 10 Ibid. 11 Ibid., sec. B. 12 United Nations General Assembly, Guidelines for the Regulation of Computerized Data Files, sec. A(7). 13 Council of Europe, CM-Rec (2017)5, June 17, 2017, Appendix I, sec. VIII. This is a revision of the 2004 standards, which were the first of their kind. 6

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