Home > Voting procedures > BULGARIA- Joint Opinion on the Draft Election Code
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Paragraph 66

X. Voting process

A. Electronic voting

Additionally, an entire range of privacy and data protection concerns are raised as Article 213(3) of the draft Code requires the system to identify voters and ensure that only voters with the right to vote are able to vote. In order to do this, the system will have to process and store personal data, which invokes the application of numerous standards for the processing of personal data through electronic means. The limited text of these articles is insufficient for establishing legal and technical guarantees required before electronic voting is introduced and before personal data is processed by the system. Further, the introduction of electronic voting should be done gradually and through piloting it in a limited number of polling stations, with contingency plans for backup voting arrangements should the electronic voting system fail. The Venice Commission and the OSCE/ODIHR recommend electronic voting not be introduced without addressing these issues and drafting legal text that is specific and detailed. The introduction of electronic voting based on the text of Articles 212-214 should be carefully reconsidered.