Cross-cutting layer · data & elections · reviewed Nov. 2, 2026

Who has the voter data—and what can it actually tell them?

Election data lives in several very different systems. States maintain official voter-registration lists. Campaigns and vendors enrich lawful voter-file data with commercial and behavioral information. Advocacy groups build their own databases and volunteer networks. In 2026, federal agencies also began collecting large voter datasets.

Do not collapse these systems into one database.

A state voter file, Data Trust, i360, Election Integrity Network, Public Interest Legal Foundation and DHS are separate entities with different purposes, authorities and data sources. A documented exchange or personnel link belongs on the map; mere similarity does not.

The baseline

Every state starts with an official registration system.

What federal law requires

The Help America Vote Act requires each state, through its chief election official, to maintain a single official statewide computerized voter-registration list. States decide many of the access rules around those lists, including who may obtain them, which fields are available and what uses are permitted.

The Election Assistance Commission notes an important boundary: voter files may include registration status, party affiliation in some states, participation history or voting method—but they do not reveal which candidate a voter chose. The secret ballot remains secret.

2011 onward · campaign data infrastructure

The voter file becomes one layer inside much larger political databases.

Data Trust and the RNC

Federal Election Commission records describe an August 2011 Data Exchange and Enhancement Agreement between the Republican National Committee and Data Trust. Under the agreement, the RNC licensed portions of its voter-list data to Data Trust and received enhanced data of equivalent fair-market value in return.

Data Trust now describes itself as core data infrastructure for Republican and conservative campaigns and says it tracks thousands of data points across hundreds of millions of individuals.

Republican National CommitteeData Trust
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i360 adds another large right-of-center data platform

i360 currently markets a political platform built on hundreds of millions of voter and consumer profiles, with targeting, modeling, canvassing and analytics tools. In 2015, The Washington Post reported a data-sharing arrangement between i360 and Data Trust, allowing data gathered in the Koch-backed advocacy network and the RNC-aligned ecosystem to flow between the two vendors under that agreement.

i360Data Trust

2020s · activist and litigation infrastructure

Voter-roll data also became a focus of permanent advocacy networks.

Election Integrity Network

Election Integrity Network says Cleta Mitchell founded it in 2021 and that the Conservative Partnership Institute incubated the organization. EIN now lists state coalitions across the country and describes permanent volunteer infrastructure focused on election law, administration, voter rolls and related policy.

Cleta MitchellElection Integrity NetworkConservative Partnership Institute
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Public Interest Legal Foundation

PILF describes itself as a public-interest law firm founded in 2012 and says it has built a nationwide database combining voter rolls for use in election litigation and research. CPI identifies Cleta Mitchell as one of PILF’s founders and its chairman.

Public Interest Legal FoundationCleta Mitchell

2025–2026 · a federal government entry point

The newest branch is different—and still contains unresolved provenance questions.

Heather Honey → DHS → HSI voter-data effort

Heather Honey moved from outside election-focused organizing into a Department of Homeland Security election-integrity role in 2025. Records produced by Homeland Security Investigations and released in 2026 state that 48.4 million records were obtained through Honey’s “independent sources of information.” The public record still does not identify the original source or sources of those 48.4 million records.

Heather HoneyU.S. Department of Homeland SecurityHSI voter-data collection effort

How to read the data layer

Five distinctions prevent bad conclusions.

1 · Registration is not vote choice

Official voter files can show registration and participation history, but never which candidate received a person’s secret ballot.

2 · Public record is not unrestricted use

States differ on who can obtain voter lists and what uses are lawful. Privacy protections also vary.

3 · Vendor models are not government records

Private political-data firms can append commercial data, modeled traits and contact history to voter-file information.

4 · Network membership is not common ownership

Coalitions can share training, tactics or meetings without sharing a corporate structure or every dataset.

5 · Unknown provenance stays unknown

When the original source of a dataset is not public, this project will not substitute a likely vendor or organization without evidence.

6 · Data quality is a separate question

The existence of a large dataset does not establish that its records are current, complete, lawfully usable for a particular purpose or sufficient to prove an allegation.

Evidence rule

A data line must specify what moved, between whom, under what documented relationship, and—when available—under what legal authority. We will not draw a line merely because two groups work on voter rolls or use similar technology.

Source ledger

The controlling records behind this layer.

Government guidanceU.S. Election Assistance Commission

Defines statewide voter-registration systems, confidentiality principles and the distinction between voter history and secret-ballot choice.

Open source ↗
Government legal recordFederal Election Commission — MUR 6888

Documents the 2011 RNC/Data Trust Data Exchange and Enhancement Agreement and Data Trust’s described commercial-data inputs.

Open source ↗
Direct organizational sourceElection Integrity Network

Documents EIN’s founding by Cleta Mitchell, CPI incubation and current state-coalition structure.

Open source ↗
Direct organizational sourcePublic Interest Legal Foundation

Describes PILF’s nationwide voter-roll database and litigation model.

Open source ↗
Produced agency recordsHSI records released by Democracy Forward

Supports the narrow claim that HSI records attributed 48.4 million records to Heather Honey’s independent sources; it does not identify those original sources.

Open source ↗