Independent audit report on the performance of the duties and functions of election officers – October 26, 2020 By-elections
Independent practitioner's reasonable assurance report on the performance of the duties and functions of election officers for the October 26, 2020 by-elections
To Mr. Stéphane Perrault, Chief Electoral Officer (CEO) of Canada, Elections Canada
We have undertaken a reasonable assurance engagement on whether deputy returning officers (DRO), poll clerks (PC)Footnote 1, registration officers (REGO) and their central poll supervisors (collectively referred to as "election officers") have, for the October 26, 2020 by-elections in the ridings of Toronto Centre (Ontario) and York Centre (Ontario), on all days of advance polling (October 16 to 19, 2020) and on ordinary polling day (October 26, 2020), properly exercised the powers conferred on them, and properly performed the duties and functions imposed on them under sections 143 to 149, 161, 162 and 169 of the Canada Elections Act (CEA or "the Act") (including the relevant updates to the Act as a result of Bill C-76 which received Royal Assent on December 13, 2018) and whether the administrative controls established by Elections Canada (EC), including manuals, training material and optimized certificates and forms (together the Criteria), were effective in supporting election officers in the performance of their duties and functions.
Management is responsible for establishing and maintaining administrative and operational controls (key and secondary) to ensure election officers have the training, tools and guidance necessary to allow them to properly exercise their duties and functions in accordance with the relevant sections of the Act, namely sections 143 to 149, 161, 162 and 169 (hereafter referred to as 'the relevant sections of the Act').
Management is responsible for establishing the Criteria (as outlined in Appendix A) and agreeing that the Criteria and reporting thresholds are suitable for this report.
Our responsibility is to express a reasonable assurance opinion on the performance of duties and functions by election officers in accordance with the relevant sections of the Act and the effectiveness of the administrative controls based on the evidence we have obtained. We conducted our reasonable assurance engagement in accordance with the Canadian Standard on Assurance Engagements (CSAE) 3001, Direct Engagements.
This standard requires that we plan and perform this engagement to obtain reasonable assurance about whether election officers properly exercised their duties and functions as outlined in the relevant sections of the Act.
Reasonable assurance is a high level of assurance but is not a guarantee that an engagement conducted in accordance with this standard will always detect a material misstatement when it exists. The nature, timing and extent of procedures selected depends on our professional judgment, including an assessment of the risks of material misstatements, whether due to fraud or error, and involves examining evidence about management's administrative and operational controls in place in accordance with the established Criteria (refer to Appendix A). We agreed the Criteria and reporting thresholds with management.
The establishment of a threshold for reporting purposes was critical during the planning of the audit. The reporting thresholds were agreed upon with management and reflected the relative importance of the control. For key controls, a deviation of 5% or more was considered a 'major finding'. For those same key controls, a deviation of 2%–4.9% was considered an 'other observation'. For secondary controls, a deviation of 11% or more was considered an 'other observation'.
The relevant sections of the Act refer only to the duties and functions performed by DROs, PCs and REGOs. The scope of the duties of election officers as prescribed in the relevant sections of the Act require election officers to register electors, request and examine each elector's proof of identity as well as administer special procedures and complete prescribed certificates and forms on all days of advance polling and on election day.
Our audit did not validate election results or assess whether election officers other than DROs, PCs and REGOs performed their specific legislative duties. Further, it did not assess performance of legislative duties that are not specifically referred to in the relevant sections of the Act; nor did it assess the administrative controls of EC beyond those implemented for purposes of supporting election officers in the conduct of their duties under the relevant sections of the Act.
We believe the evidence we have obtained is sufficient and appropriate to provide a basis for our opinion.
Our independence and quality control
We have complied with the relevant rules of professional conduct/code of ethics applicable to the practice of public accounting and related to assurance engagements, issued by various professional accounting bodies, which are founded on fundamental principles of integrity, objectivity, professional competence and due care, confidentiality and professional behaviour.
The firm applies Canadian Standard on Quality Control 1, Quality Control for Firms that Perform Audits and Reviews of Financial Statements, and Other Assurance Engagements and, accordingly, maintains a comprehensive system of quality control, including documented policies and procedures regarding compliance with ethical requirements, professional standards and applicable legal and regulatory requirements.
In our opinion, election officers have, in all significant respects, for the October 26, 2020 by-elections in the ridings of Toronto Centre (Ontario) and York Centre (Ontario), on all days of advance polling (October 16 to 19, 2020) and on ordinary polling day (October 26, 2020), properly exercised the powers conferred on them, and properly performed the duties and functions imposed on them under sections 143 to 149, 161, 162 and 169 of the CEA (including the relevant updates to the Act as a result of Bill C-76 which received Royal Assent on December 13, 2018) and the administrative controls established by EC, including manuals, training material and optimized certificates and forms were effective in supporting election officers in the performance of their duties and functions..
Purpose of statement and restriction of use and distribution
This report has been prepared in accordance with the two (2) writs dated September 18, 2020 as part of the regulatory requirements under section 164.1 (S.164.1) of the Act, to support the required reporting by the CEO under Section 533 of the CEA. Accordingly, our report is intended for EC and the CEO and may not be suitable for any other purpose.
Signed PricewaterhouseCoopers LLP
Chartered Professional Accountants
January 25, 2021
Return to source of Footnote 1 It should be noted that for the October 26, 2020 by-elections, the DRO assumed the role of the PC, as a result of the COVID-19 pandemic and the need to maintain appropriate physical distancing at an individual polling station. Despite this, we observed that, in some cases, a PC was assigned to specific polling stations.