12.02
Control Activities
Principle 12 - Implement Control Activities
Attribute 12.02 - Management establishes control activities by documenting in policies what is expected and in procedures specified actions that implement policies, to mitigate risks to achieving the entity's objectives to acceptable levels [documentation requirement].
Note: The GAO emphasized "documentation requirements."
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Jamie's Story
No examples are available to illustrate governance gaps for this attribute.
Election Anomalies
Arizona Senate Allegations
Arizona Senate allegations arose from MC's 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. The AZ AG's inspector relied on interviews to determine Information Technology (IT) practices. Evidently, no procedures were available for the inspector's review. Documented procedures ensure consistency in operations. This governance gap is most relevant to the indeterminate findings of the investigation, which are as follows:
Governance issues identified from Arizona Attorney General's Office 2020 General Election Investigation of Arizona Senate allegations of Maricopa County Election Department - Drop Box Collections issues. The AZ AG's inspector's report describes how MC should update the voter registration database to remove invalid voters based on invalid addresses. Given the significance of the update, an internal control document should have existed to describe how the voter registration database should be updated based on USPS undelivered early ballots. The AZ AG's inspector did not make any reference to such a critical update, which leads this assessment to conclude this control feature, which is needed to prevent fraud, has not been documented.
Governance issues identified from Arizona Attorney General's Office 2020 General Election Investigation of Arizona Senate allegations of Maricopa County - Signature Verification Process issues. The AZ AG inspector notes that training was developed, "which mirrors recommendations by the Arizona Secretary of State's Office." Normally, an investigator would have referenced the document that directly controls the process. Apparently, there was no MC guidance for the training, so the Arizona requirement was referenced.
