3.09
Control Environment
Principle 3: Establish Structure, Responsibility, and Authority
Attribute 3.09: Management develops and maintains documentation of its internal control system [documentation requirement].
Emphasis for documentation was added to Attribute 3.09 by the US Government Accountability Office.
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Jamie's Story
No justification for the contract changes was documented and attached to the contract.
This specific discussion of a Potential Green Book Deviation is from a sub-section titled, Motor Vehicle Department Contract. The MC management and legal team assert there are no written agreements between MC and the Arizona Motor Vehicle Department (MVD)
Contrarty to the Green Book, MC has no documentation to explain the internal controls associated with the collection of voter registration information by the MVD and subsequent transfer of sensitive information to Maricopa County. There are no written agreements according to MC managers and legal team.
The judge ruled the documents Jamie sought, excluding the Runbeck and Dominion Contracts, were not required to be created or retained by A.R.S. However, the Green Book standard succinctly states, "Management develops and maintains documentation of its internal control system [documentation requirement]."
Election Anomalies
Arizona Senate Allegations
Arizona Senate allegations arose from a failure to recognize the Arizona Senates Oversight Role. These allegations were investigated and reported on by the Arizona Attorney General's Office 2020 General Election Investigation. During the AZ AG's inspector's investigation, the inspector was told of an internal control instead of being shown the steps from a controlling procedure. Apparently, internal controls are not adequately documented to be of service to the inspector. Documentation would have been more objective evidence than an interview. This was noted in the following sub-allegations.
- Maricopa Election Management Server (2020)
- MC EMS 2020 - Election Management System Database Purged
- MC EMS 2020 - Election Files Deleted
- MC EMS 2020 - Corrupt Ballot Images
- MC EMS 2020 - Missing Ballot Images
- MC EMS 2020 - Subpoenaed Equipment Not Yet Provided
- MC EMS 2020 - Anonymous Logins
- MC EMS 2020 - Dual Boot System Discovered
- MC EMS 2020 - Operating System Logs Not Preserved
- MC EMS 2020 - Internet Connections to the EMS
There was no documentation of personnel that had completed Signature Verification Training, which seems to be an important activity. A single Level 1 Signature Verifier is being relied upon to potentially fraudulent early ballots by detecting mismatches between the early ballot signature and the voter's signature of their voter registration record. The investigator relied on MC management, the Assistant Director of Early Voting, to determine the scope and content of training.
