(Strasbourg, 2-3 December 2008)
INFORMATION REPORT ON THE ELECTRONIC VOTING IN THE FINNISH MUNICIPAL ELECTIONS
Rapporteur: Keith Whitmore (United Kingdom, R, ILDG)
Information document unanimously approved by the Congress Bureau on 1 December 2008 and submitted for information to the Standing Committee on 3 December 2008 (Autumn Session of the Congress)
1. Introduction 4
1.1. Background to the observation 4
2. The Finnish electronic voting through the prism of the fundamental principles 6
3. Operational considerations 9
4. Conclusions 10
Appendix 1 – Programme of the visit 13
Appendix 2 – Press release – 744 (2008) 16
Appendix 3 – The electronic voting terminals used in the Finnish municipal elections 17
In September 2008 the Congress Bureau decided, upon invitation, to send Ms Susan Bolam (UK, EPP/CD, R) to Finland to observe the electronic voting that, for the first time, was applied in three municipalities in the local elections of 26 October. The objective of the visit was specifically to observe this electronic voting, in order to draw lessons for the Council of Europe Member States and the Congress Secretariat alike regarding electronic voting and its observation.
Three Finnish municipalities were concerned with the pilot scheme of electronic voting (Kauniainen, Karkkila and Vihti), encompassing a total of some 34,000 voters. The electronic voting took place with the help of voting terminals placed in polling stations (including some stations also for the advance voting). In these polling stations the voters could choose between traditional or electronic voting. No distance e-voting from home was possible.
Prior to polling day Ms Susan Bolam, accompanied by Mr Fredrik Holm of the Congress Secretariat, held meetings with various stakeholders in Helsinki and on polling day the team visited 7 out of 16 concerned polling stations, throughout the three municipalities. In the evening the team was present at the central electronic vote count.
The Finnish electronic voting did not conclude in a way which satisfies the fundamental principles for democratic elections, in particular the principle of universal suffrage. A total of 232 votes were not registered because of inadequate voter use of the voting terminals (a lack of confirmation of the chosen candidate and/or a precipitated withdrawal of the voting card that had to be inserted into the terminal). This figure represents 2% of the voters who chose the electronic method. It means that neither the right to vote nor the right to be elected was ensured in a satisfactory way in this experiment. Pending a court decision, it is possible that the elections will have to be repeated in the three concerned municipalities. The electronic voting process was otherwise well organised and the applied system was nevertheless considered user-friendly by the Congress observation team.
At the same time, the Finnish experience displayed administrative features that could be applied in other countries, including the efficient organisation of polling stations with a computerised voters’ list and quick scanning of the bar code on identity cards and driver’s licences.
1.1. Background to the observation
1. On 11 September 2008 the Congress received an invitation from the Finnish authorities to become acquainted with the electronic voting in the Finnish municipal elections of 26 October 2008.
2. At its meeting on 19 September 2008, the Congress Bureau decided to respond positively to this invitation. It decided to send one representative, Ms Susan Bolam (United Kingdom) to observe the new electronic voting system, accompanied by a member of the Congress Secretariat. The study of the Finnish system also coincided with an international seminar on electronic voting in Helsinki, organised by the Finnish Chairmanship of the OSCE.
3. The objective of this undertaking was not to carry out a traditional election observation, which would have required a delegation of a certain size, but to assess the Finnish electronic experiment so as to prepare for future Congress election observations and to disseminate information on electronic voting at the European level. Many questions surround e-voting, including at the municipal level: How can transparency of the voting process, and the secrecy of the vote, be ensured?
4. On polling day 26 October Your Rapporteur, accompanied by Fredrik Holm of the Congress Secretariat, visited 7 out of the 16 polling stations that offered an electronic voting possibility. Polling stations were visited in all three municipalities concerned by the experiment.
5. Your Rapporteur wishes to cordially thank the Finnish authorities, in particular the Ministry of Justice, as well as all other partners for their extensive cooperation in the preparation of the visit and this report.
1.2. The Finnish electronic voting at municipal level
6. In the 2008 municipal elections the Finnish authorities for first time arranged electronic voting in the three municipalities of Karkkila, Kauniainen and Vihti. These municipalities count a total of 34,062 voters, who were given the chance to vote electronically at polling stations, either on election day or in advance voting (Kauniainen: 6,391; Karkkila: 7,112 and Vihti: 20,559 voters). Electronic voting was not available in any form in the other Finnish municipalities.
7. The electronic voting was exclusively carried out with voting machines at polling stations. As the data was transmitted via internet, it amounted to internet voting in a controlled environment. This electronic voting should not be confounded with distance voting via internet, which can be done from home and constitutes internet voting in an uncontrolled environment.
8. The electronic voting system was established to facilitate in particular the voting and vote count, and, eventually, to cut costs involved with elections. The Finnish Ministry of Justice largely paid for the experiment, with some cost-sharing with the three involved municipalities. A possible extension of the use of electronic voting in future elections will be considered on the basis of experience gained in these municipal elections.
9. The preparation for the electronic voting started in 2005, with more general reflection and preparations dating back to the year 2000 within the Finnish Ministry of Justice.
10. The 2008 municipal elections were the first elections in Finland to be carried out in part through electronic voting.
11. The primary legal acts for regulating the elections are the Constitution of Finland, the Election Act (714/1998) and the provisions on electronic voting included in the Act amending the Election Act (880/2006). The legislation on electronic voting is in force until the end of 2008. The possible extension of the use of electronic voting, and widening the geographical scope of the provisions, will be carried out by enacting a new legal act.1
1.4. The electronic vote
1.4.1. The voting
12. In the three concerned municipalities, the electronic voting system was in use at all advance polling stations during the period 15 to 21 October and at all polling stations on election day 26 October. One mobile voting bus with electronic voting was also in use in the advance voting. Traditional ballot voting was also taking place in the same polling stations and each voter could choose in which way to cast the ballot.
13. When voting electronically, the voter provided identification to a polling station official and received a voter card (a “smart card”) on which his or her basic voters’ list data was recorded. The voter inserted the smart card in the voting terminal, situated in a traditional voting booth, pressed the number of the candidate on the touch screen, approved it, after which the corresponding candidate data appeared. The voter then had to finally confirm the vote for the chosen candidate on the touch screen. A confirmation message appeared on the screen and returned the voter card to the polling station officials (the card contained limited data and could not be purposefully reused).
14. At best this voting procedure could be carried out rapidly (ie. under a minute). The voters’ list was electronically available for the polling station officials, who often scanned the bar code of a driver’s licence for a social security number and then enabled a voting card for electronic voting.
1.4.2. The underlying information technology applications
15. The aim of this report is not to enter into details on the information technology applied in the Finnish elections. However, some information is necessary in order to provide an assessment of the system’s utility.
16. In brief, four information technology applications were in use. First, the election authorities used the Election Official’s Application to check the person’s right to vote (and to register a ballot cast).
17. The voter then used the Voting Application to cast the ballot. This application registered the digital ballot, provided a digital signature and sent the ballot to a central server via internet. The central server saved the electronic ballot in an encrypted format until the vote count. At this stage the e-ballot contained information both about the voter and the vote.
18. Any attempt to vote twice would in all likelihood be hindered by both applications. The central server sent out a confirmation that the right to cast a ballot had been used.
19. The so-called Mixing Application was used at the vote count to decrypt the ballot, to separate the information about the vote and the voter. The Mixing Application was placed on a separate computer which allegedly had no physical connection to any other computer environment. Your Rapporteur was present when this application was used for the electronic vote count.
20. In addition, an overall Election Information System was in use to manage the basic electronic information, to crosscheck information and report results.
21. The core elements of the electronic voting system were based on the Linux operative system.
2. The Finnish electronic voting through the prism of the fundamental principles
22. In the following an attempt is made to assess the Finnish experience in the light of the fundamental election principles, as adopted by the Venice Commission at its 51st Plenary Session.2 The five main principles underlying Europe’s electoral heritage are universal, equal, free, secret and direct suffrage, at elections with regular intervals.
2.1 Universal suffrage
23. Your Rapporteur had the opportunity to cast an electronic test ballot in a polling station prior to the opening of the station on election day. The Finnish system was understandable and user-friendly, which is an important prerequisite for universal suffrage. In the opinion of Your Rapporteur the electronic voting system could not, overall, be made much simpler. However, safeguards have to be built in to ensure that the voter is clearly aware of an interrupted electronic voting process.
24. Two key issues of universal suffrage are the right to vote and the right to be elected. The Finnish electronic experiment did not function satisfactorily in either regard.
25. First, in terms of the right to vote, a total of 232 more voters were registered in the polling stations than there were votes in the electronic ballot box (across the three concerned municipalities; cp. 157 disqualified paper ballots). These voters were deprived of their right to vote, most probably through incorrect use of the voting terminals.3 It appears these voters were deprived of their right to vote unwillingly and unknowingly, contradicting this basic aspect of universal suffrage.4 However, it cannot be completely excluded that some of these incidents could have been produced on purpose by the voter, for instance to stage a protest by precipitately withdrawing the voter card from the electronic voting terminal. No information has surfaced to substantiate this possibility. On the contrary, several voters have expressed the difficulties they encountered with the voting terminals, which appeared to react slowly to touch-screen commands.5
26. Second, in terms of the right to be elected, the number of votes required for a victorious candidate was, in some cases, substantially lower than the number of non-registered electronic votes (also the case with disqualified paper ballots). In the municipalities of Kauniainen and Vihti there were draws between candidates that received the same amount of votes.6 Hence the Finnish electronic experiment did not terminate in a satisfactory way regarding the right to be elected.
27. Age is also an aspect of universal suffrage, as the right to vote must be acquired, at the latest, at the age of majority, without any subsequent annulment on age grounds. In the case of the Finnish experiment, it is conceivable that elderly voters, who were less acquainted with information technology, constituted a part of the voter group that had their votes omitted due to an inadequate handling of the electronic voting terminal (for instance by not confirming the chosen candidate and/or by withdrawing the voter card in a precipitately). Overall, the official statistics showed that the use of electronic voting correlated with the age of the voter so that the younger the voter, the more likely he/she was to use the electronic voting option.7
2.2 Equal suffrage
28. In the opinion of Your Rapporteur, the Finnish electronic voting experiment did not infringe on the right to equal suffrage.
29. In terms of equal voting rights, each voter has one vote; where the electoral system provides voters with more than one vote, each voter has the same number of votes. As a reflection, electronic voting, in extensive use, would probably enhance the possibilities to use complex electoral systems, such as preferential voting.
30. The electronic presentation provided no infringements as regards the equality of opportunity for parties and candidates.
31. In terms of equality and minorities, the electronic system provided an opportunity to carry out the voting also in Swedish, the second official language of Finland.
2.3. Free suffrage
33. Voters should also be able to obtain a confirmation of their vote and the system must be transparent. The Finnish system only provided a confirmation on-screen, whereas some other electronic voting systems leave a paper trail (“voter-verified paper trail”). In addition, the official voting instructions stated that the voters expressly had to push the “abort” button to abandon the electronic voting act. The 232 lost or non-registered votes could be due to the fact that the voting was aborted by other means than this (ie. by withdrawing the voter card and/or by omitting to confirm the candidate choice on the touch screen). These voters did not revert to traditional paper ballot voting and these incidents were only registered by comparing the number of voters who registered and obtained a voter card and the number of ballots cast.
34. Committee of Ministers Recommendation Rec (2004)11 states that voters shall be provided with an opportunity to practice any new method of e-voting before, and separately from, the moment of casting an electronic vote.8 Such measures would have had a certain cost but could potentially have reduced the problems with these non-registered votes.
35. The Venice Commission principles also prescribe that the counting preferably take place in polling stations. The Finnish electronic vote count took place in the premises of the information technology contractor, the TietoEnator company, in the presence of Your Rapporteur. There are certainly very valid technological and other reasons for this choice, but at the same time this approach raises questions about why such a core undertaking was not to a higher degree ensured by the Ministry of Justice, and on its premises. The IT contractor TietoEnator played a remarkably central part in this Finnish experiment.
36. It is also derived from the principle of free suffrage that the counting must be transparent. The methodology applied in the Finnish experiment ensured a sufficient degree of transparency. Each step of the vote count could be followed on video monitors, for instance the fact that the data transmission medium and the vote count computer were void of information prior to election data input. However, it remains a fact that it is impossible to penetrate the inner workings of an electronic vote count, even with enormous and specialised resources. This impossibility to observe a “physical vote count” must be very well managed so as not to endanger the high level of trust in the system that clearly exists in Finland.
37. Within the scope of this principle there are also possible advantages with electronic voting: there are no unused voting slips to account for and there are no possibilities for polling station officials to tamper with or in any way mark ballots.
2.4. Secret and direct suffrage
38. Whilst it is an extremely complex issue to assess, the secrecy of the suffrage seemed reasonably well protected in the Finnish electronic voting, compared to traditional ballot voting. There is no indication that the secrecy of the vote had been compromised in any way in the electronic voting.
39. The first step, privacy in the polling booth, did not differ from traditional voting. A remote new risk to the secrecy of the vote could exist in the polling booth for the those who chose to vote electronically. According to several sources, the radio frequency signals emitted by the voting terminal/touch screen could possibly be picked up nearby with the help of specialised devices, or by a small device temporarily attached to the voting terminal. It appears comparable situations have occurred previously in other countries. This risk to the secrecy of the vote should also be investigated in the future.
40. However, some principal questions need to be posed regarding the subsequent steps to ensure the process of secret suffrage.
41. The vote and the social security number of the voter were sent from the voting terminal to a central electronic ballot box in a heavily encrypted format, in a way which should not allow the two to be combined. However, Your Rapporteur was not convinced of the reasons for sending the social security number of the voter and the vote to the central server as one encrypted element. This issue needs to be revisited in the future.
42. The information remains on the vote count computer until the next elections. The representatives of the IT contractor TietoEnator also acknowledged that a copy of all these elements would remain on their server until the elections had been certified. A theoretical possibility of decrypting the information does exist, including with the use of the four separately held e-keys that were required to make the decryption and vote count computer function.
43. One may nevertheless pose the purely hypothetical question whether extraordinary events could lead to a situation where the responsible public officials, or indeed the involved computer experts, are forced to process and divulge the information on who voted how.
44. As regards the encryption and the use of the internet, the experts that Your Rapporteur consulted were neither preoccupied by the encryption nor by the use of the internet to transfer the data from the voting terminal to the central server. Some experts even stated that the internet route probably constituted “one of the safest parts of the electronic voting system”. Overall, it seemed that potential risks to the system, and to secret suffrage, predominantly could be perceived at either end of the system, ie. at the voting terminal or at the central level.
3. Operational considerations
45. In the context of an electronic vote, there need to be particular procedural safeguards to ensure that all principles of democratic elections are implemented.
46. Transparency is closely linked to free suffrage. In terms of operational standards, measures to ensure transparency were taken by the Finnish authorities, in line with Committee of Ministers Recommendation Rec (2004)11 on legal, operational and technical standards for e-voting.
47. However, more information could possibly have been provided by the Finnish authorities. Recommendation (2004)11 states that the electoral authorities shall publish an official list of the software used in an e-election. At the very least it shall indicate the software used, the versions, its date of installation and a brief description. Basic information is available on the official election website www.vaalit.fi
48. In some instances, the source code has been published by the election authorities, at least after the elections. The Finnish authorities did not have any intention to do so. Information about the system audit that preceded the elections was published, but Your Rapporteur was told that more information clearly could have been provided to the public by the authorities.
3.2. Verifiability and accountability
49. Committee of Ministers Recommendation (2004)11 prescribes that an independent body, appointed by the electoral authorities, shall verify that the e-voting system is working correctly and that all necessary security measures have been taken. It is the duty of the organising authorities to install an appropriate process of certification, and it is subsequently for international and domestic observers to assess the certification process.
50. Criticism about verifiability and accountability was voiced by representatives of non-governmental EFFI (Electronic Frontier Finland).9 According to them, much more detailed information should be made available to alleviate any fears of benign or malign information system problems. This organisation was also invited to be part of a verification process but they decided to abstain as they would have had to sign a non-disclosure agreement, which their representatives described as prohibitive.
51. The chain of custody of all the involved software and hardware should also be made clear.
3.3. Reliability and security
52. It was also acknowledged by TietoEnator representatives that the encrypted data on voters and their choices remained on company servers for days after the elections.
53. The way to proceed in the event of a local and/or central failure needs to be very clear. Your Rapporteur got the impression that the procedures to some extent remained unclear to polling station chairpersons. When some polling station chairpersons were asked how to act in case of information technology failures, they replied, inter alia, that they would call on the representatives of the IT contractor, TietoEnator.
54. Identified representatives of the contractor, the TietoEnator company, were present in many polling stations. Your Rapporteur did not see any intervention by these representatives but, according to some polling station chairpersons, they would act as a first port of call in the event of information technology failures. A central helpline had also been established in each concerned municipality. If applied on a larger scale, the presence of representatives by the IT contractor in the polling stations would not be possible. It also poses a principal question on whether this is an appropriate measure, and contributed to the overall impression that the IT contractor played a remarkably important role in the Finnish experiment.
55. Finally, in terms of security, the polling machines could be rendered useless by damage to the touch screen, the local computer or the power supply. A concerted effort by several individuals/voters with malign intentions could severely interrupt the activities of a polling station and force all voting to be carried out by traditional ballot.
4.1. The Finnish electronic voting experiment
56. It should be acknowledged that the Finnish authorities put significant resources into ensuring that the electronic voting would be carried out in line with national legislation and international standards, including Recommendation (2004)11 of the Committee of Ministers of the Council of Europe.
57. Nevertheless, the electronic experiment did not in a satisfactory way meet the requirements derived from the fundamental principles for democratic elections. In terms of the principle of universal suffrage, 232 voters were deprived of their right to vote. The right to be elected was also subject to a proportionally significant infringement, as the number of non-registered electronic votes on several occasions exceeded the number of votes necessary to secure a winning ticket (also the case with disqualified paper ballots). The number of non-registered votes is significant in proportion to the total number of electronic ballots cast (1,9%; 12 234 electronic ballots successfully cast). This issue can also be seen in the light of the principle of free suffrage, as the election authorities’ instructions did not refer to this possibility of aborting the vote.
58. The measures to ensure transparency could also benefit from a review. A voter-verified paper trail could have helped avoiding the encountered problems, facilitated a possible recount and increased transparency. More general information about the experiment, in particular system certification, could also possibly have been made available by the organising authorities.
59. Your Rapporteur remains unconvinced of the necessity to transfer each vote and the voter’s social security number to the central server as one encrypted element. It would also have enhanced the confidence in the process if the electronic vote count had been ensured on Ministry of Justice premises rather than at the information technology contractor.
60. Procedural clarity, including in case of breakdown, is also a crucial element. Interviewed polling station chairpersons gave different replies to how they would proceed in case of system failure, including power cuts. Representatives of the IT contractor were present in many of the involved polling stations, a remedy which obviously will not be applicable, or perhaps desirable, on a larger scale. From a different perspective, a voter-verified paper trail (a print line or ticket) could enable a manual verification and increase voter confidence in case of a problem. The Finnish experiment did not employ any voter-verified paper trail.
61. Overall, electronic voting poses a number of new risks and challenges while it may speed up procedures like the vote count. The fact that electronic and traditional voting is offered in parallel offers an important function of checks and balances. Whilst the risk of actually manipulating the election results remains very low, all risks have to be managed very well in order to avoid any erosion of the confidence in the electoral administration. An electronic voting procedure will inevitably remain less comprehensible for the electorate.
62. However, the Finnish elections displayed some other electronic features with a great potential for application elsewhere. Other computerisation than the actual e-voting can already substantially facilitate the voting process, such as the computerised voters’ list and scanning of the social security bar code on Finnish identity cards and driver’s licences. These features clearly enhanced the voting process, regardless of whether it was done electronically or by traditional paper ballot. In countries where registration is a prerequisite for voting, the advantages of computerisation of the voters’ list could be significant, in particular if a voter can register and verify his/her information on-line. A computerised voters’ list can improve reliability and transparency, even when used in combination with traditional ballot voting.
4.2. The added value of electronic voting
63. The Finnish Ministry of Justice emphasised the following expected results for the electronic voting experiment: faster and more secure advance voting (no more transport or handling of sealed ballots), faster vote count, reduced work for election authorities and, in the long run, cost savings. The main reason for introducing electronic voting in Finland nevertheless seemed to have been the fact that it was part of the government programme (including that of the previous government).
64. The main objective for applying e-voting in any form needs to be very clear. The cost of a secure and reliable e-system can be excessively high in relation to the advantage brought by it, including the fact that it most often, like in Finland, will have to be applied in parallel with a traditional polling system. Significant resources are also required around the core system, notably large-scale information dissemination to citizens and system testing. Sufficient system testing, including on ordinary citizens, may have been a weakness in the Finnish electronic experiment.
65. Overall, Your Rapporteur remains unconvinced of how the introduction of a parallel system of electronic voting, like the one in Finland, will reduce the workload of the election authorities and produce cost savings, even in the medium- to long-term.
66. The added value of electronic voting could partially lie in future developments that may increase the opportunity to vote. When large segments of the voters feel comfortable with an electronic system, it could be applied at select locations so as to try to increase the opportunity to vote (for instance shopping malls, as already tried in some countries). If an electorate is at ease with an electronic voting system it will also offer possibilities to easily vote on multiple issues, which is the case in the USA. There should also be added value to the democratic process, which initially lies, for example, in the fact that unclear ballots cannot be cast in an electronic vote. Electronic voting could also, potentially, favour precise but more complicated electoral systems, such as preferential voting.
67. Considerable human resources are also required for electronic voting. Apart from all the central level information technology and other expertise, this type of voting leaves considerable and complex responsibilities with the polling station officials, who need to possess computer skills. It would reasonably not be enough to have only one skilled official per polling station. The careful handling of passwords and other material should also be emphasised.
4.3. Future observation of elections which include electronic voting
68. The monitoring of the Finnish electronic voting provided great insights into the advantages and disadvantages of electronic voting. Most aspects of electronic voting can be purposefully observed without in-depth technological knowledge. Despite some initial problems in several countries, e-voting is in all likelihood going to be pursued in various forms and on an ever growing scale, in pace with technological developments. In many cases two alternative voting systems will be used in parallel, as was the case in Finland in October 2008. This requires the Congress, and any other observer institution, to build up a capacity for meaningfully observing parallel election formats, which is why it is necessary for the Congress to continue to observe e-voting as an important element of modern democracy. The Venice Commission and especially the Council for Democratic Elections, which includes the OSCE, could be the correct fora for further development of guidelines.
Programme of the visit of Ms Susan Bolam (United Kingdom)
CONGRESS OBSERVATION OF THE ELECTRONIC VOTING IN FINLAND
Thursday 23 October
Arrival Susan Bolam 23:50 (KLM 1171 from Amsterdam)
Arrival Fredrik Holm 22:30 (LH 3106 from Frankfurt)
Friday 24 October
09:00 Working breakfast
Preparation of the forthcoming meetings
13:00-14:30 Briefing at the Ministry of Justice (MoJ),
Address: Eteläesplanadi 10, Helsinki
15:00-17:00 Meeting with representatives of the Asssociation of Finnish Local and Regional Authorities
Saturday 25 October
10:00-12:00 Meeting with representatives of Electronic Frontier Finland (EFFI)
Preparation of polling day.
Sunday 26 October – Election Day
07:30-13:30 Departure from hotel for a chosen polling station to observe the start-up procedures for electronic voting
Observation of the electronic voting in the three concerned municipalities
Participation in the OSCE Chairmanship seminar on electronic voting:
10:00 onwards Registration of participants at the Marina Congress Center
11:30-13:00 Lunch hosted by the Finnish Chairmanship
13:00-13:30 Opening session
13:30-14:00 Introduction to the Finnish Electoral System
14:10 Optional: Departure by bus from Marina Congress Center to follow the municipal elections in municipalities where e-voting takes place.
Municipalities of Karkkila, Kauniainen, and Vihti; all located close to Helsinki. Participants will be divided into four groups.
Return by bus to Marina Congress Center
19:00 – 21:00, Opening of the electronic ballot box
Address: TietoEnator Oyj, Tietotie 6, Espoo
19:30 onwards Following the broadcast on elections and election results
Monday 27 October
Participation in the OSCE Chairmanship seminar:
9:00-12:00 E-voting experiences in the participating States of the OSCE
Introduction to the Finnish e-voting system; first experiences from the piloting project in the municipal elections of 2008
Comments based on experiences from participating States
12:00-14:00 Lunch hosted by the Finnish Chairmanship
14:00-16:00 Developing international e-voting standards and monitoring
16:15-16:45 Concluding session - prospects for e-voting in the OSCE area?
Press release - 744(208)
A demonstration of the Finnish electronic voting can be found on the election site of the Ministry of Justice: www.vaalit.fi.
The electronic voting terminals used in the Finnish municipal elections of October 2008.
1 Information provided on the website of the Ministry of Justice: http://www.vaalit.fi/42735.htm
2 Venice, 5-6 July 2002 – «Guidelines on elections», see, for example, document CDL-AD (2002) 23 rev “Code of Good Practice in Electoral Matters”.
3 See, for example, the information on website of the Finnish Ministry of Justice: http://www.om.fi/Etusivu/Ajankohtaista/Uutiset/1224166604122 Complaints requesting the annulment of the election results in the three concerned municipalities have been lodged with the Helsinki administrative tribunal (see, e.g., an article in the largest Finnish daily paper, Helsingin Sanomat, of 11 November 2008, available at www.hs.fi . The complaints could potentially result is a re-run of the elections in the three municipalities.
4 As a comparison, 132 paper ballots were disqualified in the three concerned municipalities in the preceding 2004 local elections, amounting to 0,68% of the votes cast. The equivalent figure for 2008 (157 disqualified paper ballots and 232 non-registered electronic votes) amounts to a total of 389 or 1,8% of votes cast, practically trebling the proportion of disqualified votes compared to the previous elections.
5 See, for example, Helsingin Sanomat 11 November 2008 (Finnish only), available at www.hs.fi
7 Information provided to the Congress by the Finnish Ministry of Justice.
8 Committee of Ministers Rec (2004)11, article 22. Available at www.coe.int