Module 7

Procuring and Evaluating Custody Systems

By the end, participants can write evaluable requirements for a custody system

  • 90 minutes
  • Workshop
  • Prerequisite: M1–M6

Learning objectives

  1. Write evaluable requirements for a custody system
  2. Distinguish substantive security claims from marketing
  3. Identify the certification and compliance frameworks that actually apply

Content

  • Certification landscape, stated accurately: VVSG 2.0 applies to voting systems — equipment that marks, casts, or tabulates. Custody and tracking systems sit outside that boundary, and VVSG 2.0 in fact requires election systems be air-gapped from the voting system. What this means for the buyer: no EAC certification gate, therefore a normal software procurement timeline — but also no federal certification to lean on, so your own evaluation has to be real.
  • Frameworks that do apply: SOC 2 Type II, StateRAMP, NIST SP 800-53, EI-ISAC participation, independent penetration testing.
  • Requirements-writing workshop (40 min): participants draft five evaluable requirements. The standard: could a third party determine objectively whether a vendor meets this?
  • The question bank — twelve questions to ask every custody vendor:
  • Who holds the signing keys, and can the county hold its own?
  • Where is the commitment anchored, and who can verify it without trusting you?
  • Can any administrator delete a record? Under what process, and is that deletion itself logged?
  • What happens to our data if you go out of business? Is source escrowed?
  • Show me a proof failing verification. What does the operator see?
  • What is your penetration test cadence, and will you share the report under NDA?
  • What is your data residency and hosting boundary?
  • How do you handle the retention/privacy conflict architecturally?
  • What is your degraded-mode operation if USPS data is unavailable?
  • How many jurisdictions have deployed this in a live federal election?
  • What is your incident response SLA and notification obligation?
  • Who on your team has run an election?

Run the exercise

Assessment

Draft requirements section for a hypothetical RFP, peer-reviewed in session. ---