Case 1:17-cv-01320-CKK Document 38-1 Filed 07/17/17 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
ELECTRONIC PRIVACY INFORMATION
CENTER,

Civil Action No. 1:17-cv-1320 (CKK)

Plaintiff,
v.
PRESIDENTIAL ADVISORY
COMMISSION ON ELECTION
INTEGRITY, et al.,
Defendants.

DECLARATION OF CHARLES CHRISTOPHER HERNDON
I, Charles C. Herndon, declare as follows:
1.

I am the Director of White House Information Technology (“WHIT”) and Deputy

Assistant to the President. I am the senior officer responsible for the information resources and
information systems provided to the President, Vice President and Executive Office of the
President. I report to White House Deputy Chief of Staff for Operations and Assistant to the
President, and through him to the Chief of Staff and the President. I am part of what is known as
the White House Office. This declaration is based on my personal knowledge and upon
information provided to me in my official capacity.
2.

A number of components make up the Executive Office of the President,

including the White House Office (also referred to as the Office of the President). Components
of the White House Office include the President’s immediate staff, the White House Counsel’s
Office and the Staff Secretary’s Office. The White House Office serves the President in the
performance of the many detailed activities incident to his immediate office, and the various

 Case 1:17-cv-01320-CKK Document 38-1 Filed 07/17/17 Page 2 of 3

Assistants and Deputy Assistants to the President aid the President in such matters as he may
direct. My role is to ensure the effective use of information resources and systems to the
President. I am also a member of the Executive Committee for Presidential Information
Technology, as established in the March 19, 2015, Presidential Memorandum creating my
position. See, https://obamawhitehouse.archives.gov/the-press-office/2015/03/19/presidentialmemorandum-establishing-director-white-house-information-te. The Executive Committee is
chaired by the Deputy Chief of Staff Operations.
3.

I was asked by the Office of the Vice President to assist in creating a mechanism

by which data could be securely loaded and stored within the White House computer systems.
To do that I repurposed an existing system that regularly accepts personally identifiable
information through a secure, encrypted computer application within the White House
Information Technology system.
4.

States that wish to provide information to the Presidential Advisory Commission

on Election Integrity (“Commission”) can email the Commission to request an access link. Once
a staff member verifies the identity of the requester and the email address, a one-time unique
uniform resource locator (“URL”) link will be emailed to that state representative. Data can be
uploaded via that one-time link to a server within the domain electionintegrity.whitehouse.gov.
Authorized members of the Commission will be given access to the file directory identified to
house the uploaded information. Once the files have been uploaded, there is no further transfer
of the data from that location. The technology is similar to a shared folder in Microsoft
SharePoint.
5.

The Commission will receive dedicated laptops, which can access the data

provided by states through the White House network over an SSL (Secure Sockets Layer)

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connection. The SSL connection ensures that all data passed between the web server and
browsers remain private and secure. The laptops use Personal Identity Verification (PIV) and
the data at rest is encrypted.
6.

The Executive Committee for Information Technology will have no role in this

data collection process. The U.S. Digital Service (which is within the Office of Management and
Budget) will also have no role, nor will any federal agency. The only people who will assist are
a limited number of my technical staff from the White House Office of Administration. They
will have access to the data, but all access will be logged and recorded by our network
monitoring tools.
7.

I can confirm, based on information provided to me from the Department of

Defense, that the data the state of Arkansas uploaded to the Army’s SAFE site has been deleted
without ever having been accessed by the Commission.
I declare under penalty of perjury that the foregoing is true and correct to the best of my
knowledge.

***

Executed this 16th day of July 2017.
Digitally signed by CHARLES HERNDON
DN: c=US, o=U.S. Government, ou=Executive Office
of the President, cn=CHARLES HERNDON,
0.9.2342.19200300.100.1.1=11001003426249
Date: 2017.07.17 06:36:16 -04'00'

___________
Charles C. Herndon

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