Consultant's Security and Telecommunications Test Report

Dominion Democracy Suite 5.19 Security and Telecommunications Test Report for California Secretary of State CAF-23003-STR-01 Prepared for: Vendor Name Dominion Voting Systems Vendor System Democracy Suite 5.19 Prepared by: 4720 Independence St. Wheat Ridge, CO 80033 303-422-1566 www.SLICompliance.com Accredited by the Election Assistance Commission (EAC) for Selected Voting System Test Methods or Services Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Copyright © 2025 by SLI ComplianceSM, a Division of Gaming Laboratories International, LLC Revision History Date Release Author Revision Summary July 29th, 2024 1.0 A. Nestico Initial Release D. Martin October 11th, 2024 2.0 D. Martin Update for issue resolutions Disclaimer The information reported herein must not be used by the client to claim product certification, approval, or endorsement by NVLAP, NIST, or any agency of the Federal Government. Trademarks • SLI is a registered trademark of SLI Compliance. • All products and company names are used for identification purposes only and may be trademarks of their respective owners. California Certification Page 2 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report TABLE OF CONTENTS OVERVIEW ......................................................................................................................................... 4 PHASE I – DOCUMENTATION REVIEW ........................................................................................... 4 2.1.1 SECURITY ................................................................................................................................. 5 6.2 DESIGN, CONSTRUCTION, AND MAINTENANCE REQUIREMENTS ....................................................... 5 7.2.2 ACCESS CONTROL IDENTIFICATION ............................................................................................ 6 7.3.1 POLLING PLACE SECURITY ........................................................................................................ 6 7.3.2 CENTRAL COUNT LOCATION SECURITY ....................................................................................... 6 7.4.1 SOFTWARE AND FIRMWARE INSTALLATION .................................................................................. 6 7.4.2 PROTECTION AGAINST MALICIOUS SOFTWARE ............................................................................ 8 7.4.3 SOFTWARE DISTRIBUTION AND SETUP VALIDATION ..................................................................... 8 7.4.4 SOFTWARE DISTRIBUTION.......................................................................................................... 8 7.4.5 SOFTWARE REFERENCE INFORMATION ....................................................................................... 9 7.4.6 SOFTWARE SETUP VALIDATION .................................................................................................. 9 7.8.1 ACCESS CONTROL .................................................................................................................... 9 PHASE II – FUNCTIONAL SECURITY TESTING ............................................................................ 10 2.1.1 SECURITY ............................................................................................................................... 11 2.1.5.1 OPERATIONAL REQUIREMENTS ............................................................................................. 12 5.4.3 IN-PROCESS AUDIT RECORDS .................................................................................................. 13 7.2.1 GENERAL ACCESS CONTROL ................................................................................................... 14 7.2.2 ACCESS CONTROL IDENTIFICATION .......................................................................................... 15 7.2.3 ACCESS CONTROL AUTHENTICATION ........................................................................................ 15 7.2.4 ACCESS CONTROL AUTHORIZATION ......................................................................................... 17 7.3 PHYSICAL SECURITY MEASURES ................................................................................................. 17 7.3.1 POLLING PLACE SECURITY ...................................................................................................... 18 7.3.2 CENTRAL COUNT LOCATION SECURITY ..................................................................................... 19 7.4.1 SOFTWARE AND FIRMWARE INSTALLATION ................................................................................ 19 7.4.2 PROTECTION AGAINST MALICIOUS SOFTWARE .......................................................................... 21 7.4.3 SOFTWARE DISTRIBUTION AND SETUP VALIDATION ................................................................... 21 7.4.4 SOFTWARE DISTRIBUTION........................................................................................................ 21 7.4.5 SOFTWARE REFERENCE INFORMATION ..................................................................................... 22 7.4.6 SOFTWARE SETUP VALIDATION ................................................................................................ 23 7.6 TELECOMMUNICATIONS AND DATA TRANSMISSION ....................................................................... 27 7.6.1 MAINTAINING DATA INTEGRITY ................................................................................................. 27 7.6.2 ELECTION RETURNS ................................................................................................................ 28 7.7.3 ELECTRONIC AND PAPER RECORD STRUCTURE ........................................................................ 28 7.7.4 EQUIPMENT SECURITY AND RELIABILITY ................................................................................... 29 7.8.2 DATA INTERCEPTION AND DISRUPTION ..................................................................................... 29 PHASE III – TELECOMMUNICATIONS AND DATA TRANSMISSION TESTING.......................... 30 6.1.2 DATA TRANSMISSION ............................................................................................................... 31 California Certification Page 3 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 6.2.1 CONFIRMATION ....................................................................................................................... 32 OPEN-ENDED VULNERABILITY TESTING .................................................................................... 32 7.5.1 OEVT SCOPE AND PRIORITIES ................................................................................................ 33 7.5.2 OEVT RESOURCES AND LEVEL OF EFFORT .............................................................................. 35 7.5.3 CONTEXT OF OEVT TESTING................................................................................................... 37 7.5.4 FAIL CRITERIA ......................................................................................................................... 38 7.5.5 OEVT REPORTING REQUIREMENTS ......................................................................................... 39 FINAL REPORT ................................................................................................................................ 40 Overview This test report provides results for the security and telecommunications testing of the Dominion Democracy Suite 5.19 (Dominion DS 5.19). Security and telecommunications testing covered: • Top-level system design and architecture. • System documentation and procedures. • Testing of relevant software and operating system configuration for pertinent vulnerabilities. • Testing of hardware, including examination of unused hardware ports and security measures applied to those ports. • Testing of system communications, including encryption of data as well as protocols and procedures for access authorization. Testing was implemented without any prior knowledge of the source code. The testing was divided into four phases. • Phase I – Documentation Review included review of all pertinent documents for appropriate processes and procedures for implementing a secure system. This included a review of the system design and architecture. • Phase II – Functional Security Testing included testing of relevant software, operating systems, and hardware configurations. • Phase III – Telecommunications and Data Transmission Testing included testing of all telecommunications aspects of the system. • Phase IV – Open-Ended Vulnerability Testing included open-ended vulnerability testing of the entire system. Phase I – Documentation Review California Certification Page 4 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report During Phase I testing, documentation was reviewed to verify and validate the following requirements: • Top-level system design and architecture. • System documentation and procedures. During Phase I testing, documentation was reviewed to verify and validate the following California Voting System Standards (CVSS) requirements: • 2.1.1 Security • 6.2 Design, Construction, and Maintenance Requirements • 7.2.2 Access control identification • 7.3.1 Polling place security • 7.3.2 Central count location security • 7.4.1 Software and firmware installation • 7.4.2 Protections against malicious software • 7.4.3 Software distribution and setup validation • 7.4.4 Software Distribution • 7.4.5 Software Reference Information • 7.4.6 Software Setup Validation See the applicable section below for more details on these requirements and the review results. During Phase I testing, an issue log of any errors and omissions found in the documentation or anomalies encountered was maintained. 2.1.1 Security System security is achieved through a combination of technical capabilities and sound administrative practices. To ensure security, all systems shall: g. Provide documentation of mandatory administrative procedures for effective system security. Results: Review of the Technical Data Package (TDP) validated that the requirement was satisfactorily covered. 6.2 Design, Construction, and Maintenance Requirements Design, construction, and maintenance requirements for telecommunications represent the operational capability of both system hardware and software. These capabilities shall be considered basic to all data transmissions. California Certification Page 5 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.2.2 Access Control Identification a. The voting system shall identify users and processes to which access is granted and the specific functions and data to which each entity holds authorized access. b. Voting system equipment that implements role-based access control shall support the recommendations for Core RBAC in the ANSI INCITS 359-2004 American National Standard for Information Technology Role Based Access Control document. c. Voting system equipment shall allow the administrator group or role to configure the permissions and functionality for each identity, group, or role to include account and group/role creation, modification, and deletion. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.3.1 Polling Place Security For polling place operations, manufacturers shall develop and provide detailed documentation of measures to enable poll workers to physically protect and perform orderly shutdown of voting equipment to counteract vandalism, civil disobedience, and similar occurrences. The measures shall allow the immediate detection of tampering with vote casting devices and precinct ballot counters. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.3.2 Central Count Location Security Manufacturers shall develop and document in detail the measures to be taken in a central counting environment. These measures shall include physical and procedural controls related to the handling of ballot boxes, preparing of ballots for counting, counting operations and reporting data. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.4.1 Software and Firmware Installation The system shall meet the following requirements for installation of software, including hardware with embedded firmware: California Certification Page 6 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report a. Air Gap Architecture i. Every voting system shall be capable of being deployed in a segregated dual-installation architecture to protect against propagation of viruses. The architecture shall allow elections officials to use one or more, permanent server(s) and set of central-office voting devices, known to be running unaltered, certified software and firmware to create memory cards before each election and to use another, physically separate “sacrificial” server and set of voting devices after the election to tabulate results and generate reports. The architecture shall allow transfer of the election definition and tally database from the permanent server(s) to the sacrificial server using a write-once medium, such as a CD-R. The voting system architecture shall allow each installation to use its own Ethernet network, port server, and central-office vote-recording units, including any DRE and optical scan units, permitting the two installations to be segregated and air-gapped to ensure that there are no cross connections. An air gap is established by keeping two installations/networks physically separate and seeing that no device attached to the sacrificial installation/network is connected (directly or indirectly) to the first network, ensuring that data cannot flow from one installation/network to the other. ii. The TDP for the voting system shall provide full procedures and instructions, to be incorporated into the Official Use Procedures for the voting system, to implement the segregated dual-installation architecture. b. Voting and Tabulating Units i. If software is resident in the system as firmware, the manufacturer shall require and state in the system documentation that every device is to be retested to validate each ROM prior to the start of elections operations. ii. To prevent alteration of executable code, no software shall be permanently installed or resident in the voting system unless the system documentation states that the jurisdiction must provide a secure physical and procedural environment for the storage, handling, preparation, and transportation of the system hardware. iii. The voting system bootstrap, monitor, and device-controller software may be resident permanently as firmware, provided that this firmware has been shown to be inaccessible to activation or control by any means other than by the authorized initiation and execution of the vote counting program, and its associated exception handlers. iv. The election-specific programming may be installed and resident as firmware, provided that such firmware is installed on a component (such California Certification Page 7 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report as a computer chip) other than the component on which the operating system resides. v. After initiation of Election Day testing, no source code or compilers or assemblers shall be resident or accessible. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.4.2 Protection against Malicious Software Voting systems shall deploy commercial-off-the-shelf (COTS) protection against the many forms of threats to which they may be exposed such as file and macro viruses, worms, Trojan horses, and logic bombs. Manufacturers shall develop and document the procedures to be followed to ensure that such protection is maintained in a current status. Virus and malware protection software and updates shall be installed using transportable portable media only and shall not be installed by download from the Internet. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.4.3 Software Distribution and Setup Validation Subsections 7.4.4, 7.4.5, and 7.4.6 specify requirements for the distribution of voting system software and the setup validation performed on voting system equipment. These requirements are applicable to voting systems that have completed certification testing. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.4.4 Software Distribution The manufacturer shall document all software including voting system software, third party software (such as operating systems and drivers) to be installed on the certified voting system, and installation programs. a. The documentation shall have a unique identifier (such as a serial number or part number) for the following set of information: documentation, software manufacturer name, product name, version, the certification application number of the voting system, file names and paths or other location information (such as storage addresses) of the software. b. The documentation shall designate all software files as static, semi-static or dynamic. Results: Review of the TDP validated that the requirement was satisfactorily covered. California Certification Page 8 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 7.4.5 Software Reference Information (Pertinent excerpt being addressed from CVSS requirement 7.4.5) a. The manufacturer shall provide the NSRL, any California certified escrow facility, pursuant to Title 2, Division 7, Chapter 6 of the California Code of Regulation, and the Office of the Secretary of State with a copy of the software installation disk, including the executable binary images of all third- party software. Further, the manufacturer shall deposit the source code, tools, and documentation, to allow the complete and successful compilation of a system in its production/operation environment. i. The manufacturer shall document that the process used to verify the software distributed on unalterable storage media is the certified software by using the reference information provided by the NSRL or other designated repository before installing the software. c. The manufacturers shall document to whom they provide voting system software. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.4.6 Software Setup Validation g. Setup validation methods shall verify the contents of all system storage locations (e.g., system registers, variables, files, etc.) containing election specific information (e.g., ballot style, candidate registers, measure registers, etc.). ii. The manufacturer shall document the default values of all system storage locations that hold election specific information. Results: Review of the TDP validated that the requirement was satisfactorily covered. 7.8.1 Access Control The accredited testing laboratory shall conduct tests of system capabilities and review the access control policies and procedures submitted by the manufacturer to identify and verify the access control features implemented as a function of the system. Specific activities to be conducted by the S-ATA shall include: a. A review of the manufacturer’s access control policies, procedures and system capabilities to confirm that all requirements have been addressed completely. California Certification Page 9 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Results: Review of the TDP validated that the requirement was satisfactorily covered. Phase II – Functional Security Testing Phase II testing included: • Testing of relevant software and operating system configurations for pertinent vulnerabilities. • Testing of hardware, including examination of unused hardware ports and the security measures applied to those ports. During Phase II, functional tests were exercised in order to verify and validate the following CVSS requirements: • 2.1.1 Security • 2.1.5 System Audit • 5.4.3 In-process Audit Records • 7.2.1 General access control • 7.2.2 Access control identification • 7.2.3 Access control authentication • 7.2.4 Access control authorization • 7.3 Physical security measures • 7.3.1 Polling place security • 7.3.2 Central count location security • 7.4.1 Software and firmware installation • 7.4.2 Protection against malicious software • 7.4.3 Software distribution and setup validation • 7.4.4 Software distribution • 7.4.5 Software Reference Information • 7.4.6 Software Setup Validation • 7.6 Telecommunications and data transmission • 7.6.1 Maintaining Data Integrity • 7.6.2 Election Returns • 7.8.1 Access Control • 7.8.2 Data Interception and Disruption See the applicable section below for more details on these requirements and the test results. California Certification Page 10 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report An issue log of any errors, omissions, or anomalies found in the documentation was maintained. 2.1.1 Security System security is achieved through a combination of technical capabilities and sound administrative practices. To ensure security, all systems shall: a. Provide security access controls that limit or detect access to critical system components to guard against loss of system integrity, availability, confidentiality, and accountability. b. Provide system functions that are executable only in the intended manner and order, and only under the intended conditions. c. Use the system's control logic to prevent a system function from executing if any preconditions to the function have not been met. d. Provide safeguards in response to system failure to protect against tampering during system repair or interventions in system operations. e. Provide security provisions that are compatible with the procedures and administrative tasks involved in equipment preparation, testing, and operation. f. Incorporate a means of implementing a capability if access to a system function is to be restricted or controlled. g. Provide documentation of mandatory administrative procedures for effective system security. Testing performed: The overall functionality of the system was assessed based on these six overreaching functional security requirements: 1. All access control mechanisms will be examined to determine if they are adequate to guard against system integrity, availability, confidentiality, and accountability. 2. The system functions will be examined to determine that the system functions in only the intended manner. 3. All system control logic will be examined to determine if system functions can be executed without preconditions to the functions being met. 4. Examination of the systems safeguards in response to system failures to determine if there is protection against tampering during a system repair or interventions. 5. Confirm that the security provisions are compatible with procedures, administrative tasks during equipment preparation, and election system testing and operation. 6. Determine if system capabilities can be implemented during system functions while the system is restricted or controlled. California Certification Page 11 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing resulted in the requirements 2.1.1.b, and 2.1.1.c, being identified as partially met. Certain components could be configured to prevent the Event Log from recording data as expected. However, users can easily verify the status of event logging by checking the Event Viewer. If the Event Log is prevented from recording, the Event Viewer will indicate the Event Log status and identify which user performed specific actions. Testing was performed and confirmed that the status of the event logging service can be identified by browsing directly to the Event Viewer and confirming the associated error message. The overall associated security risk is classified as low severity due to documented procedural mitigations, limiting account usage to non-administrative user accounts during day-to-day usage, and the ability to identify the Event Log status and identify which user performed specific actions. 2.1.5.1 Operational Requirements Audit records shall be prepared for all phases of election operations performed using devices controlled by the jurisdiction or its contractors. These records rely upon automated audit data acquisition and machine-generated reports, with manual input of some information. These records shall address the ballot preparation and election definition phase, system readiness tests, and voting and ballot-counting operations. The software shall activate the logging and reporting of audit data as described below. a. Voting system equipment shall record activities through an event logging mechanism. b. Voting system equipment shall enable file integrity protection for stored log files as part of the default configuration. c. The voting system equipment logs shall not contain information that, if published, would violate ballot secrecy or voter privacy or that would compromise voting system security in any way. e. Voting system equipment shall log all normal and abnormal events. i. Voting system equipment shall ensure that event logging cannot be disabled. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) California Certification Page 12 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Results: Testing concluded that the system’s configuration was insufficient to fully meet the requirements of sections 2.1.5.1.e, 2.1.5.1.e.i. Certain components could be configured to prevent the Event Log from recording data as expected. However, users can easily verify the status of event logging by checking the Event Viewer. If the Event Log is prevented from recording, the Event Viewer will indicate the Event Log status and identify which user performed specific actions. Testing was performed and confirmed that the status of the vent logging service can be identified by browsing directly to the Event Viewer and confirming the associated error message. The overall associated security risk is classified as low severity due to documented procedural mitigations, limiting account usage to non- administrative user accounts during day-to-day usage, and the ability to identify the Event Log status and identify which user performed specific actions. 5.4.3 In-process Audit Records iv. Notification of system login or access errors, file access errors, and physical violations of security as they occur, and a summary record of these events after processing. Testing performed: As all other requirements were being tested, the Audit log was reviewed to verify that appropriate records were recorded for the events occurring. The examination also included: • Attempts to modify or corrupt audit logs / records. • Attempts to disable or turn off audit logging capabilities. • Attempts to falsify audit logs located on removable election media. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing concluded that the system’s configuration was insufficient to fully meet the requirements. Certain components could be configured to prevent the Event Log from recording data as expected. However, users can easily verify the status of event logging by checking the Event Viewer. If the Event Log is prevented from recording, the Event Viewer will indicate the Event Log status and identify which user performed specific actions. Testing was performed and confirmed that the status of the vent logging service can be identified by browsing directly to the Event Viewer and confirming the associated error message. The overall associated security risk is classified as low severity due to documented procedural mitigations, limiting account usage to non-administrative user accounts during day-to-day usage, and the California Certification Page 13 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report ability to identify the Event Log status and identify which user performed specific actions. 7.2.1 General Access Control a. Voting system equipment shall provide access control mechanisms designed to permit authorized access to the voting system and to prevent unauthorized access to the voting system. i. Access control mechanisms on the Election Management System (EMS) shall be capable of identifying and authenticating individuals permitted to perform operations on the EMS. b. Voting system equipment shall provide controls that permit or deny access to the device’s software and files. c. The default access control permissions shall implement the minimum permissions needed for each role or group identified by a device. d. The voting device shall prevent a lower-privileged process from modifying a higher-privileged process. e. An administrator of voting system equipment shall authorize privileged operations. f. Voting system equipment shall prevent modification to or tampering with software or firmware through any means other than the documented procedure for software upgrades. Testing performed: • System wide authentication checks, including both positive and negative testing. To verify that the systems under examination allowed authorized users the ability to complete tasks while preventing all unauthorized users from accessing critical controls or processes. • Attempts to access systems files or software via an unauthorized method or process. • System wide permission checks to determine if user accounts and passcodes only allowed the appropriate levels of permission / roles to perform the task at hand. • Examined Solution specific users and roles to confirm permissions and task / actions. • Attempts to escalate privileges from a lower privileged account in an attempt to perform or access roles or tasks not specifically assigned to users. California Certification Page 14 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report • Examined the system to determine if the software or firmware could be tampered with or modified through other means besides the documented procedure. • Enumerated each system as able, pulling audit logs, firewall rules, running processes, network configurations, user lists, security settings. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Testing validated that the requirement was satisfactorily covered. 7.2.2 Access Control Identification a. The voting system shall identify users and processes to which access is granted and the specific functions and data to which each entity holds authorized access. b. Voting system equipment that implements role-based access control shall support the recommendations for Core RBAC in the ANSI INCITS 359-2004 American National Standard for Information Technology Role Based Access Control document. c. Voting system equipment shall allow the administrator group or role to configure the permissions and functionality for each identity, group, or role to include account and group/role creation, modification, and deletion. Testing performed: • Confirmed that the documented users and roles are the same as those documented in the TDP. • Confirmed all solution roles and responsibilities. • Confirmed administrative group’s roles and permissions. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. 7.2.3 Access Control Authentication The following authentication requirements apply to all voting system equipment. a. Voting system equipment shall authenticate users prior to granting them access to system functions or data. California Certification Page 15 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report b. When private or secret authentication data is stored in voting system equipment, the data shall be protected to ensure that the confidentiality and integrity of the data is not violated. c. Voting system equipment shall allow the administrator group or role to set and change passwords, pass phrases, and keys. d. Voting system equipment shall allow privileged groups or roles to be disabled and allow new individual privileged groups or roles to be created. e. Voting system equipment shall lock out groups, roles, or individuals after a specified number of consecutive failed authentication attempts within a predefined time period. f. Voting systems shall allow the administrator group or role to configure the account lock out policy, including the time period within which failed attempts must occur, the number of consecutive failed access attempts allowed before lock out, and the length of time the account is locked out. g. If the voting system uses a username and password authentication method, the voting system shall allow the administrator to enforce password strength, histories, and expiration. h. The voting system shall allow the administrator group or role to specify password strength for all accounts, including minimum password length, use of capitalized letters, use of numeric characters, and use of non- alphanumeric characters. i. The voting system shall enforce password histories and allow the administrator to configure the history length. j. Voting system equipment shall ensure that the username is not used in the password. k. Voting systems shall provide a means to automatically expire passwords in accordance with the voting jurisdiction’s policies. Testing performed: • Attempts to access system functions and resources without successful authentication to the operating system or Dominion DS 5.19 system. • Attempts to find extra authentication data from system storage including hard drives, USB, Compact Flash, and Secure Digital (SD) removable media. • Verified the system equipment allows the administrator to change all passwords, pass phrases, and keys, if applicable. • Verified that the system(s) have the ability to lock out accounts after a specified number of failed authentication attempts. California Certification Page 16 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report • Confirmed and tested the system’s password complexity, strength, lockout, history, length, and expiration requirements. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. 7.2.4 Access Control Authorization a. Voting systems shall ensure that only authorized roles, groups, or individuals have access to election data. b. Voting systems shall explicitly authorize the subject’s access based on access control lists or policies. c. Voting systems shall explicitly deny the subject’s access based on access control lists or policies. During the examination, the access control authorization capabilities of all the systems were examined to determine if the systems sufficiently provided controls for authorization. Testing performed: • Verified that the system only allows authorized roles, groups, and individuals access to election data. • Verified that the system has access levels based on roles, control lists, or policies. • Verified that the system successfully denies access to the system based on roles, lists, or policies. • All the systems successfully protected the system BIOS settings from tampering which prevented all attempts to boot from unauthorized devices and system configuration settings from being changed at a BIOS level. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. 7.3 Physical Security Measures a. Any unauthorized physical access shall leave physical evidence that an unauthorized event has taken place. California Certification Page 17 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report b. Voting systems shall only have physical ports and access points that are essential to voting operations and to voting system testing and auditing. c. An event log entry that identifies the name of the affected device shall be generated if a component connected to a piece of voting system equipment is disconnected while polls are open. d. Ports disabled while polls are open shall only be re-enabled by authorized administrators. e. Access points, such as covers and panels, shall be secured by locks or tamper evident seals or tamper resistant countermeasures shall be implemented so that system owners can monitor access to voting system components through these points. f. Ballot boxes shall be designed such that any unauthorized physical access results in physical evidence that an unauthorized event has taken place. During the examination of the physical security measures, all the systems were physically secured as they normally would be during a live election. Testing performed: • Attempts to circumvent all physical security features, including picking of locks and attempts to circumvent or bypass security seals and security screws. • Examined and tested all ports and connectors. • Disconnected devices and examined audit logs, as applicable, to determine if auditing of device disconnection was present. • Identified and examined every cover, panel, and access compartment. • Attempts to circumvent all ballot boxes to add, remove, or destroy paper ballots. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. 7.3.1 Polling Place Security For polling place operations, manufacturers shall develop and provide detailed documentation of measures to enable poll workers to physically protect and perform orderly shutdown of voting equipment to counteract vandalism, civil disobedience, and similar occurrences. The measures shall allow the immediate detection of tampering with vote casting devices and precinct ballot counters. California Certification Page 18 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Testing performed: Tests were performed to verify that the documented measures provide adequate polling place security, including: • Physical examination of ballot box security. • Verification of documented procedures • Confirmed physical characteristics of device protection including locks, security seals, and cases. • Attempted loading of modified election data • Examined ballot printers for the ability to manipulate printer settings. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC) Results: Testing validated that the requirement was satisfactorily covered. 7.3.2 Central Count Location Security Manufacturers shall develop and document in detail the measures to be taken in a central counting environment. These measures shall include physical and procedural controls related to the handling of ballot boxes, preparing of ballots for counting, counting operations and reporting data. Testing performed: Tests were performed to verify that the documented measures provide adequate central count location security, including: • Confirmed physical characteristics of device protection including locks, security seals, and cases. • Examined EMS and ICC desktop configurations to verify that the desktops provided secure network communications between devices. • Examined EMS and ICC desktop configurations to verify that unauthorized users were not able to access operating system components. • Verified that the EMS and ICC desktop configurations were not able to be manipulated through the ability to boot to unauthorized devices or circumvent in-place access controls. • Verified all COTS equipment such as scanners and printers. Applicable to: ImageCast® Central (ICC) Results: Testing validated that the requirement was satisfactorily covered. 7.4.1 Software and Firmware Installation (Pertinent excerpt being addressed from CVSS requirement 7.4.1) California Certification Page 19 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report The system shall meet the following requirements for installation of software, including hardware with embedded firmware: b. Voting and Tabulating Units ii. To prevent alteration of executable code, no software shall be permanently installed or resident in the voting system unless the system documentation states that the jurisdiction must provide a secure physical and procedural environment for the storage, handling, preparation, and transportation of the system hardware. iii. The voting system bootstrap, monitor, and device-controller software may be resident permanently as firmware, provided that this firmware has been shown to be inaccessible to activation or control by any means other than by the authorized initiation and execution of the vote counting program, and its associated exception handlers. iv. The election-specific programming may be installed and resident as firmware, provided that such firmware is installed on a component (such as a computer chip) other than the component on which the operating system resides. v. After initiation of Election Day testing, no source code or compilers or assemblers shall be resident or accessible. Testing performed: • Confirmed solutions air gap architecture including, but not limited to, private Ethernet networking configurations and protections and the ability to protect the system against foreign software being introduced to the system. • Confirmed that the Dominion DS 5.19 system contained no source code, compilers, or assemblers. • Confirmed that all boot operations were password protected and that the Dominion DS 5.19 system’s monitoring and device controller software is inaccessible to activation or control. • Confirmed that none of the software is permanently installed or resident in the Dominion DS 5.19 system. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. California Certification Page 20 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 7.4.2 Protection against Malicious Software Voting systems shall deploy commercial-off-the-shelf (COTS) protection against the many forms of threats to which they may be exposed such as file and macro viruses, worms, Trojan horses, and logic bombs. Manufacturers shall develop and document the procedures to be followed to ensure that such protection is maintained in a current status. Virus and malware protection software and updates shall be installed using transportable portable media only and shall not be installed by download from the Internet. Testing performed: Tests were performed to verify that COTS products are implemented to protect against malicious software, as described in voting system manufacturer documentation, including: • Verifying protection against malicious software and files. • Ability to run unauthorized software. • Ability to run unauthorized scripts (PowerShell, Python, Batch). • Attempts to circumvent Whitelisting technology. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. 7.4.3 Software Distribution and Setup Validation Subsections 7.4.4, 7.4.5, and 7.4.6 specify requirements for the distribution of voting system software and the setup validation performed on voting system equipment. These requirements are applicable to voting systems that have completed certification testing. Testing performed: This requirement is met by successful validation of 7.4.4, 7.4.5 and 7.4.6. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing determined that the requirement was satisfactorily covered. 7.4.4 Software Distribution The manufacturer shall document all software including voting system software, third party software (such as operating systems and drivers) to be installed on the certified voting system, and installation programs. California Certification Page 21 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report a. The documentation shall have a unique identifier (such as a serial number or part number) for the following set of information: documentation, software manufacturer name, product name, version, the certification application number of the voting system, file names and paths or other location information (such as storage addresses) of the software. b. The documentation shall designate all software files as static, semi-static or dynamic. Testing performed: During the examination of the Dominion DS 5.19 solution, the systems were reviewed to confirm: • Verification and examination of third-party software for vulnerabilities. • Verification and examination of all software and file paths. • Confirmation of unique identifiers of software. • Examination of static, semi-static, and dynamic content of the systems. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing determined that the requirement was satisfactorily covered. 7.4.5 Software Reference Information b. The voting system equipment shall be designed to allow the voting system administrator to verify that the software is the certified software by comparing it to reference information produced by the NSRL or another designated repository. Testing performed: Tests were performed to verify that the software can be verified to meet the National Software Reference Library (NSRL) reference information, including: • Verification of trusted build process. • Verification and examination of system verification process for integrity checking the certified software. • Verified the process for certifying system software. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. California Certification Page 22 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 7.4.6 Software Setup Validation a. Setup validation methods shall verify that only authorized software is present on the voting equipment. Authorized software is COTS software components needed to run the voting system and voting software components identified by the manufacturer as authorized. b. The manufacturer shall provide a method to comprehensively list all software files that are installed on voting systems. i. This method shall list version names and numbers for all application software on the voting system. ii. This method should list the date of installation for all application software on the voting system. c. Setup validation methods shall include a software verification method that ensures that the voting system software has not been modified illegitimately. i. The voting systems shall include any supporting software and hardware necessary to conduct the software verification method. ii. The manufacturer shall document the process used to conduct the software verification method. iii. The software verification method shall not modify the voting system software on the voting system. d. Voting systems shall include a software verification method that either verifies software prior to installation or a method that verifies software using an external interface. Voting systems may include both software verification methods. Voting systems may provide ancillary setup validation methods, including methods for verifying or identifying installed software, other than those described in this section. There are no specific requirements for ancillary setup validation methods. However, any method intended to serve as the voting system software verification method must meet the requirements outlined in this section. e. Voting systems which implement a software verification method that verifies software prior to installation shall meet the following requirements. i. The voting system shall contain no more than one method for installing, updating, or removing software on a system. o Voting system equipment shall prevent processes from installing software except for the one specific software installation process identified by the manufacturer. California Certification Page 23 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report o The voting system manufacturer shall document the procedures for installing, updating, and removing voting system software, configuration files, and data files. o Voting system equipment shall prevent processes from installing, updating or removing software while the polls are open. o Voting system equipment shall prevent the execution of software not installed using the specified software installation process. ii. The voting system shall only allow authenticated administrators to install software on voting equipment. The voting system shall present the administrator with a description of the software change being performed, including: o A list of all applications and/or file names being updated. o The type of action performed on each application and/or file (e.g., new application/file, deletion or overwriting of existing file). iii. Voting system equipment shall store the current version identification of all software installed on the voting system equipment. o The current version identification shall be included as part of reports created by the voting system equipment. o The current version identification shall be displayed as part of the voting system equipment start up process. iv. The process for installing, updating and removing software shall make software changes based on information contained in software update packages. Software update packages shall minimally contain the following information: o A unique identifier for the software update package. o Names of the applications or files modified during the update process. o Version numbers of the applications or files modified during the update process. o Any software prerequisites or dependencies for the software involved in the update. o A description of the type of action performed on each application and/or file (e.g., new application/file, deletion or overwriting of existing file). o The binary data of any new or updated files involved in the update process. California Certification Page 24 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report v. The software update package shall be formatted in a non-restrictive, publicly available format. Manufacturers shall provide a specification describing how they have implemented the format with respect to the manufacturer’s specific voting devices and data, including such items as descriptions of elements, attributes, constraints, extensions, syntax and semantics of the format, and definitions for data fields and schemas. vi. Software update packages shall be digitally signed by using a NIST approved algorithm with a security strength of at least 112 bits. vii. The software installation process shall verify digital signatures, software version identification, software prerequisites and dependencies, and manufacturer specific authorization information associated with the software before the software is installed. The software installation process shall not install software with invalid digital signatures, version numbers, or manufacturer specific authorization information, and shall not install software on systems that do not meet the update requisites. viii. The voting system shall have the capability to prevent the installation of previous versions of applications or files. ix. The software installation process shall result in information being stored in the voting system equipment’s log such that altering or deleting log entries or the log was detected. x. The minimum information to be included in the voting system equipment log shall be: o Success or failure of the software installation process. o Cause of a failed software installation (such as invalid version identification, digital signature, etc.). o Application or file name(s), and version number(s). o A description of the type of action performed on each application and/or file (e.g., new application/file, deletion or overwriting of existing file). o A cryptographic hash of the software update package using FIPS 1402 level 1 or higher validated cryptographic module. f. If software is verified after being installed on the voting system equipment, the voting system equipment shall provide an external interface to the location of the voting system software for software verification purposes. i. The external interface: o Shall be protected using tamper evident techniques. California Certification Page 25 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report o Shall have a physical indicator showing when the interface is enabled and disabled. o Shall be disabled during voting. o Should provide a direct read-only access to the location of the voting system software without the use of installed software ii. The verification process should be able to be performed using COTS software and hardware available from sources other than the voting system manufacturer. o If the process uses hashes or digital signatures, then the verification software shall use a FIPS 140-2 level 1 or higher validated cryptographic module. o The verification process shall either (a) use reference information on unalterable storage media received from the repository or (b) verify the digital signature of the reference information on any other media. g. Setup validation methods shall verify the contents of all system storage locations (e.g., system registers, variables, files, etc.) containing election specific information (e.g., ballot style, candidate registers, measure registers, etc.). i. The manufacturer should provide a method to query the voting system to determine the value contained in all system storage locations containing election specific information. Testing performed: Tests were performed to verify that the installation process for each system component is robust and maintains the integrity of the voting system. These tests included: • Confirmed process for verification of Dominion Desktop and device software. • Verified system installation processes and procedure. • Verified system trusted build procedures. • Examined the desktop environment to confirm that there is no unauthorized software on the device. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. California Certification Page 26 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 7.6 Telecommunications and Data Transmission There are four areas that must be addressed by telecommunications and data transmission security capabilities: access control, data integrity, detection and prevention of data interception, and protection against external threats. 7.6.1 Maintaining Data Integrity Voting systems that use telecommunications to communicate between system components and locations are subject to the same security requirements governing access to any other system hardware, software, and data function. a. Voting systems that use electrical or optical transmission of data shall ensure the receipt of valid vote records is verified at the receiving station. This should include standard transmission error detection and correction methods such as checksums or message digest hashes. Verification of correct transmission shall occur at the voting system application level and ensure that the correct data is recorded on all relevant components consolidated within the polling place prior to the voter completing casting of his or her ballot. i. Cryptography used to verify the receipt of vote records shall use NIST approved algorithms with security strength of at least 112 bits. Message Authentication Code (MAC) keys shall have a security strength of at least 112 bits. Testing performed: Tests were performed to verify that data is properly encrypted, and that receipt is verified, including: • Security testing captured and examined all network traffic between each of the separate networked devices and determined that all traffic between the server and clients utilize encrypted traffic. • Determined that all results files and election relevant data that is transmitted or contained in removable media are encrypted or digitally signed. • Examination of the desktop isolated networks determined that all communications between devices require authentication and that any unauthorized devices accidentally or maliciously added to the secured networking environments would not be able to interact with the Dominion Desktop server/client systems. • Vulnerability scans of desktop systems were conducted both as a trusted and untrusted machine in the network. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC) California Certification Page 27 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Results: Testing validated that the requirement was satisfactorily covered. 7.6.2 Election Returns If the voting system provides access to election returns or interactive inquiries, the system shall: a. Allow authorized administrators the ability to disable or restrict access to election returns (for equipment that operates in a central counting environment). This requirement applies as well to polling place equipment that contains a removable memory module or that may be removed in its entirety to a central place for the consolidation of polling place returns. b. Design voting system software and its security environment such that data accessible to interactive queries resides in an external file or database created and maintained by the elections software under the restrictions applying to any other output report: i. The output file or database has no provision for write access back to the system. ii. Persons whose only authorized access is to the file or database are denied write access, both to the file or database, and to the system. Testing performed: Tests were performed to determine that if the system provides access to election returns or interactive queries, then the authorized administrators can disable or restrict access, and that the data resides in an external file or database governed by the voting system. Tests included: • Attempts to compromise database components to modify or alter results. • Attempts to modify or change results files on removable media. • Attempts to change results in transmission between count server and client. • Attempts to physically compromise device and desktop systems in an attempt to compromise storage media. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ) Results: Testing validated that the requirement was satisfactorily covered. 7.7.3 Electronic and Paper Record Structure The examination included: • Verification that all devices and associated components of the voting system used FIPS 140-2 encryption and was enabled correctly. California Certification Page 28 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report • Digital signatures are generated using NIST-approved digital signature algorithms with a security strength of at least 112 bits. • Additional verification that data at rest and in transit remain encrypted. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Testing validated that the requirement was satisfactorily covered. 7.7.4 Equipment Security and Reliability The examination included: • Verification that all printers are physically connected via a standard, publicly documented printer port using a standard communication protocol. • That all printer access is secure using tamper-evident seals or physical security measures. • That any break or interruption in communication between the voting machine and printer is detected and recorded in a system event log. • That the printer cannot communicate with any system or machine other than the voting machine it is connected to. • The printer can only function as a printer and contains no network capability. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Testing validated that the requirement was satisfactorily covered. 7.8.2 Data Interception and Disruption For systems that use telecommunications, as provided for in section 6 of the Standards and consistent with California law, to transmit official voting data, the S- ATA shall review, and conduct tests of, the data interception and prevention safeguards specified by the manufacturer in its TDP. The S-ATA shall evaluate safeguards provided by the manufacturer to ensure their proper operation, including the proper response to the detection of efforts to monitor data or otherwise compromise the system. Individual voter-facing components are not networked, nor do they transmit individual voting results. This includes ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2). The only telecommunication in use is a closed ethernet (physically connected) network configuration comprised of the EMS components at a central count location. Operating system-level transmissions provided appropriate encryption, receipt validation, and data integrity protections. California Certification Page 29 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Testing performed: Testing included verification of operating system level transmissions regarding appropriate encryption, receipt validation, and data integrity, including: • Capture and examination of all network traffic between each of the separate networked devices to determine encryption used for connection security. • The examination determined that all results files and election relevant data either transmitted or contained in removable media are encrypted or digitally signed. • Examination of the desktop isolated networks determined that all communications between devices require authentication and that any unauthorized devices accidentally or maliciously added to the secured networking environments would not be able to interact with the Dominion Desktop server/client systems. • Vulnerability scanning of desktop systems. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Testing validated that the requirement was satisfactorily covered. Phase III – Telecommunications and Data Transmission Testing During Phase III, tests were exercised in order to verify and validate the following requirements: • Testing of system communications, including encryption of data, as well as protocols and procedures for access authorization. In this phase, tests were exercised in order to verify and validate the following CVSS requirements: • 6.1.2 Data Transmission • 6.2.1 Confirmation See the applicable section below for more details on these requirements and the test results. An issue log of any errors, omissions, or anomalies found in the documentation was maintained. California Certification Page 30 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 6.1.2 Data Transmission These requirements apply to the use of telecommunications to transmit data for the preparation of the system for an election, the execution of an election, and the preservation of the system data and audit trails during and following an election. While this section does not assume a specific model of voting system operations and does not assume a specific model for the use of telecommunications to support such operations, it does address the following types of data, where applicable: Voter Authentication: Coded information that confirms the identity of a voter for security purposes for a system that transmits votes individually. Ballot Definition: Information that describes to a voting machine the content and appearance of the ballots to be used in an election. Vote Count: Information representing the tabulation of votes at any level within the control of the jurisdiction, such as the polling place, precinct or central count. List of Voters: A listing of the individual voters who have cast ballots in a specific election. Additional data transmissions used to operate a voting system in the conduct of an election, but not explicitly listed above, are also subject to the requirements of this section. Testing performed: All networked devices were scrutinized to determine if networked systems and the data transmissions between the networked systems were vulnerable to compromise, and if the data transmissions were encrypted. Testing included: • Nessus vulnerability scans were conducted on all equipment that were connected to the private Dominion DS 5.19 isolated networks, as an external untrusted entity. • Testing to confirm that the operating system level transmissions provided appropriate encryption, receipt validation, and data integrity. • Testing to confirm that the ability to export Root certificates didn’t include the private key. • Network packet capture and analysis, to determine transmission encryption, and to determine if authentication was performed in the clear. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Testing validated that the requirement was satisfactorily covered. California Certification Page 31 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 6.2.1 Confirmation Confirmation occurs when the system notifies the user of the successful or unsuccessful completion of the data transmission, where successful completion is defined as accurate receipt of the transmitted data. To provide confirmation, the telecommunications components of a voting system shall notify the user of the successful or unsuccessful completion of the data transmission. In the event of unsuccessful transmission, the user shall be notified of the action to be taken. Testing performed: Testing was performed to verify appropriate confirmation of data transmission to the user and actions to be taken, if any, including: • Nessus vulnerability scans were conducted on all equipment connected to the private Dominion DS 5.19 system networks. • Operating system level transmissions provide confirmation. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC) Results: Testing validated that the requirement was satisfactorily covered. • This requirement was determined to be not applicable for polling place devices. • Nessus vulnerability scans were conducted on all equipment that were connected to the private EMS network. These included the Election Management System (EMS), ImageCast® Adjudication (ADJ), and ImageCast® Central (ICC). • Application-level transmissions provided confirmation of transmission. Open-Ended Vulnerability Testing Vulnerability testing is an attempt to bypass or break the security of a system or a device. Like functional testing, vulnerability testing can identify security weaknesses but cannot verify the security measures in place. As such, vulnerability testing is leveraged as a part of functional security testing to identify potential points within the system requiring further review. Open-ended vulnerability testing (OEVT) is conducted without the confines of a pre-determined test suite. It instead relies heavily on the experience and expertise of the OEVT Team Members, their knowledge of the system, its component devices and associated vulnerabilities, and their ability to exploit those vulnerabilities. The goal of OEVT is to discover architecture, design, and implementation flaws in the system that may not be detected using systematic functional, reliability, and security testing and which may be exploited to change the outcome of an election, California Certification Page 32 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report interfere with voters’ ability to cast ballots or have their votes counted during an election, or compromise the secrecy of the vote. OEVT also includes attempts to discover logic bombs, time bombs, or other Trojan Horses that may have been introduced into the system hardware, firmware, or software for said purposes. 7.5.1 OEVT Scope and Priorities a. Scope of open-ended vulnerability testing – The scope of open-ended vulnerability testing (OEVT) shall include the voting system security during all phases of the voting process and shall include all manufacturer supplied voting system use procedures. The scope of OEVT includes but is not limited to the following: i. Voting system security; ii. Voting system physical security while voting devices are: o In storage; o Being configured; o Being transported; and o Being used. iii. Voting system use procedures. b. Focus of open-ended vulnerability testing – OEVT Team members shall seek out vulnerabilities in the voting system that might be used to change the outcome of an election, to interfere with voters’ ability to cast ballots or have their votes counted during an election or to compromise the secrecy of vote. c. OEVT General Priorities – The OEVT team shall prioritize testing efforts based on: i. Threat scenarios for the voting system under investigation; ii. The availability of time and resources; iii. The OEVT team’s determination of easily exploitable vulnerabilities; and iv. The OEVT team’s determination of which exploitation scenarios are more likely to impact the outcome of an election, interfere with voters’ ability to cast ballots or have their votes counted during an election or compromise the secrecy of the vote. v. All threat scenarios must be plausible in that they should not be in conflict with the anticipated implementation, associated use procedures, the workmanship requirements (assuming those requirements were all California Certification Page 33 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report met) or the development environment specification as supplied by the manufacturer in the TDP; vi. Open-ended vulnerability testing should not exclude those threat scenarios involving collusion between multiple parties including manufacturer insiders. It is acknowledged that threat scenarios become less plausible as the number of conspirators increases; vii. It is assumed that attackers may be well resourced and may have access to the system while under development; viii. Threats that can be exploited to change the outcome of an election and flaws that can provide erroneous results for an election should have the highest priority; ix. Threats that can cause a denial of service during the election should be considered very high priority; x. Threats that can compromise the secrecy of the vote should be considered of high priority; xi. A threat to disclosure or modification of metadata (e.g., security audit log) that does not change the outcome of the election, does not cause denial of service during the election, or does not compromise the secrecy of ballot should be considered of lower priority; xii. If the voting device uses COTS products, then the OEVT team should also investigate publicly known vulnerabilities; and xiii. The OEVT team should not consider the voting device vulnerabilities that require Internet connectivity for exploitation if the voting device is not connected to the Internet during the election and otherwise. However, if the voting device is connected to another device which in turn may have been connected to the Internet (as may be the case of electronic poll books), Internet based attacks may be plausible and should be investigated. Testing performed: • Confirmation the testing effort was scoped to the priorities outlined including: o tester time and materials. o all COTS hardware and software. o all custom hardware and software. o vulnerability ranking and analysis. o vulnerabilities compromising confidentiality, integrity, or availability. • Generation of, and testing to, a list of common vulnerabilities for exploitation. California Certification Page 34 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Review of the OEVT scope and priorities requirements confirmed that the test effort was appropriately designed and performed to effectively test the security of voting system components. 7.5.2 OEVT Resources and Level of Effort a. OEVT team resources - The OEVT team shall use the manufacturer supplied Technical Data Package (TDP) and User documentation, have access to voting devices configured similar to how they are to be used in an election, and have access to all other material and tools necessary to conduct a thorough investigation. Materials supplied to the OEVT team shall include but not be limited to the following: i. Threat analysis describing threats mitigated by the voting system; ii. Security architecture describing how threats to the voting system are mitigated; iii. High level design of the system; iv. Any other documentation provided to an EAC voting system testing laboratory or S-ATA, if applicable; v. Source code; vi. Operational voting system configured for election, but with the ability for the OEVT team to reconfigure it; vii. Testing reports from the developer and from the testing laboratory including previous OEVT results; viii. Tools sufficient to conduct a test lab build; and ix. Procedures specified by the manufacturer as necessary for implementation and secure use. b. Open-ended vulnerability team establishment - The test lab shall establish an OEVT team of at least 3 security experts and at least one election management expert to conduct the open-ended vulnerability testing. c. OEVT Team Composition: Security Experts - The OEVT team shall have at least one member with 6 or more years of experience in the area of software engineering, at least one member with 6 or more years of experience in the area of information security, at least one member with 6 or more years of experience in the area of penetration testing and at least one member with 6 or more years of experience in the area of voting system security. California Certification Page 35 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report d. OEVT Team Composition: Election Management Expert - The OEVT team shall have at least one member with at least 8 years of experience in the area of election management. The OEVT team shall consult with an elections expert, designated by the Secretary of State, who is familiar with election procedures, how the voting systems are installed and used, and how votes are counted. e. OEVT team knowledge - The OEVT team knowledge shall include but not be limited to the following: i. Complete knowledge of work done to date on voting system design, research and analysis conducted on voting system security, and known and suspected flaws in voting systems; ii. Complete knowledge of threats to voting systems; iii. Knowledge equivalent to a bachelor’s degree in computer science or related field; iv. Experience in design, implementation, security analysis, or testing of technologies or products involved in voting system; and v. Experience in the conduct and management of elections. f. OEVT level of effort: test plan - In determining the level of effort to apply to open-ended vulnerability testing, the test lab shall take into consideration the size and complexity of the voting system; any available results from the “close ended” functional, security, and usability testing activities and laboratory analysis and testing activities; the number of vulnerabilities found in previous security analyses; and testing of the voting system and its prior versions. g. OEVT level of effort: commitment of resources - The OEVT team shall examine the system for a minimum of 12 staff weeks. Testing performed: • Confirmation that VSTL resources are compliant with requirements. • Confirmation of team composition and knowledge compliant with requirements. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA) Results: Review of the OEVT resources and level of effort requirements confirmed that the test team was appropriately equipped to evaluate the Dominion DS 5.19 voting system’s security. It was confirmed that the security team was allotted less than 12 staff weeks for testing. California Certification Page 36 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report 7.5.3 Context of OEVT Testing a. Context of testing - Open ended vulnerability testing shall be conducted within the context of a process model describing a specific implementation of the voting system and a corresponding model of plausible threats. b. Adequate system model - The OEVT team shall verify that the manufacturer provided system model sufficiently describes the intended implementation of the voting system. c. Adequate threat model - The OEVT team shall verify that the threat model sufficiently addresses significant threats to the voting system. Significant threats are those that could: i. Change the outcome of an election; ii. Interfere with voters’ ability to cast ballots or have their votes counted during an election; or iii. Compromise the secrecy of vote. OEVT team may modify the manufacturer’s threat model to include additional, plausible threats. Testing performed: • Confirmation that OEVT testing was performed based on voting system design, documentation, and implementation procedures. • Confirmation that the manufacturer provided complete and accurate information within the TDP and documentation. • Confirmation that tested system security weaknesses have measurable impact on critical election data or processes. • Performed penetration testing on voting system components. • Utilized functional security findings to identify system security flaws. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Review of the OEVT testing context requirements confirmed that the test effort tested all appropriate voting system devices and applications and effectively evaluated threats to the voting system in simulated production environments. The following list of findings were discovered during open- ended vulnerability testing. • Non-voter-facing components were observed to contain operating system account configurations with a single user account that contained administrative privileges. The overall risk classification is low severity with a low likelihood considering documented California Certification Page 37 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report procedural mitigations, limiting account usage to non- administrative user accounts during day-to-day usage. 7.5.4 Fail Criteria a. OEVT fail criteria: violation of requirements - The voting device shall fail open ended vulnerability testing if the OEVT team finds vulnerabilities or errors in the voting device that violate requirements in the Standards. While the OEVT is directed at issues of device and system security, a violation of any requirement can lead to failure. The S-ATA shall report an OEVT failure if any of the following are found: i. Evidence that any single person can cause a violation of a voting system security goal (e.g., integrity of election results, privacy of the voter, availability of the voting system), assuming that all other parties follow procedures appropriate for their roles as specified in the manufacturer’s documentation; ii. Manufacturer's documentation fails to adequately document all aspects of system design, development, and proper usage that are relevant to system security. This includes but is not limited to the following: o System security objectives; o Initialization, usage, and maintenance procedures necessary to secure operation; o All attacks the system is designed to resist or detect; and o Any security vulnerabilities known to the manufacturer. iii. Use of a cryptographic module that has not been validated against FIPS 140-2; iv. Ability to modify electronic event logs without detection; v. A VVPR that has an inaccurate or incomplete summary of the cast electronic vote; vi. Unidentified software on the voting system; vii. Identified software which lacks documentation of the functionality it provides to the voting device; viii. Access to configuration file without authentication; ix. Ability to cast more than one ballot within a voting session; x. Ability to perform restore operations in Activated State; xi. Enabled remote access in Activated State; and/or xii. Ballot boxes without appropriate tamper evidence countermeasures. California Certification Page 38 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report b. Threat model: failure - Voting systems shall fail open-ended vulnerability testing if the manufacturer’s model of the system along with associated use procedures and security controls does not adequately mitigate all significant threats as described in the threat model. The OEVT team may use a threat model that has been amended based on their findings in accordance with 7.5.4.3.c. c. OEVT fail criteria: critical flaws - The voting device shall fail open ended vulnerability testing if the OEVT team provides a plausible description of how vulnerabilities or errors found in a voting device, or the implementation of its security features could be used to: i. Change the outcome of an election; ii. Interfere with voters’ ability to cast ballots or have their votes counted during an election; or iii. Compromise the secrecy of vote without having to demonstrate a successful exploitation of said vulnerabilities or errors. Testing performed: • Confirmation that testing performed accurately tested to and failed the appropriate OEVT requirements as described by the CVSS. • Confirmation that all security findings pertain to specific voting system components and highlight a failure to mitigate a security threat. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Based on the noted findings, review of all functional security testing and additional OEVT testing confirmed the failure of OEVT requirements. However, all findings have been determined to have either no impact on system security, or are limited to a low severity risk classification. 7.5.5 OEVT Reporting Requirements a. OEVT reporting requirements - The OEVT team shall record all information discovered during the open-ended vulnerability test, including but not limited to: i. Names, organizational affiliations, summary qualifications, and resumes of the members of the OEVT; ii. Time spent by each individual on the OEVT activities; iii. List of hypotheses considered; iv. List of hypotheses rejected and rationale; California Certification Page 39 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01 Dominion Democracy Suite 5.19 California Certification Security and Telecom Test Report v. List of hypotheses tested, testing approach, and testing outcomes; and vi. List and description of remaining vulnerabilities in the voting system: o A description of each vulnerability including how the vulnerability can be exploited and the nature of the impact; o For each vulnerability, the OEVT team should identify any Standards requirements violated; and o The OEVT team should flag those vulnerabilities as serious if the vulnerability can result in the violation of one or more Standards requirements; a change of the outcome of an election; or a denial of service (lack of availability) during the election. Testing performed: • Confirmation that testing documentation and reports include required detail. • Confirmation that testing methodology aligns with industry accepted penetration testing frameworks. Applicable to: Election Management System (EMS), ImageCast® Adjudication (ADJ), ImageCast® Central (ICC), ImageCast® Evolution (ICE), ImageCast® X (ICX), ImageCast® Precinct2 (ICP2), ImageCast® Voter Activation (ICVA). Results: Review of the Performed functional security and OEVT testing confirmed sufficient adherence to OEVT reporting requirements. All findings resulting from OEVT testing are included in this report. Final Report Completion of the CVSS requirements examination and the Open-Ended Vulnerability Testing (OEVT) portion resulted in five CVSS requirements being noted as insufficiently met (2.1.1.b, 2.1.1.c, 2.1.5.1.e, 2.1.5.1.e.i, and 5.4.3), and one security findingwas noted under OEVT (7.5.3). All findings are noted in the results of their relevant requirements in the sections above. Neither OEVT finding pertains to a voter-facing device. All findings have either no impact on system security or are limited to a low severity risk classification. It should also be noted that proper, secure utilization of the voting system solution is reliant upon properly trained personnel, as well as following all processes and procedures set forth by the voting system vendor to ensure properly configured and secured equipment for use in a live election environment. End of Security and Telecommunications Test Report California Certification Page 40 of 40 Security and Telecom Test Report v1.0 Report Number CAF-23003-STR-01