Imaging of Financial Documents
As discussed in the section Source Documents and the Audit Trail, it is important that source documents supporting financial transactions posted to the Financial Information System are easily accessible. As detailed in the section on Records Management, the source document could be an expense reimbursement form with receipts, a bank deposit slip, a journal entry form, or numerous other source documents.
In the past, most issues surrounding access to source documents were related to the appropriate file plan for paper documents, including how long to keep them in current files and when to archive or destroy them.
Recently, technological improvements, combined with the relatively low cost of imaging / storing documents electronically has made this option attractive to departments. While departments can choose to scan their source documents, the original paper document(s) must be retained and continue to be maintained such that they are easily accessible.
The following sections provide details surrounding the issues in this area, and the policy regarding the destruction of original paper documents:
Policy on Imaging Financial Documents
Why are original paper documents still required when a scanned copy is available?
When will approval to destroy original paper documents be given?
Policy on Imaging Financial Documents
At the University of Toronto, departments are required to maintain original documents in accordance with the U of T File Plan. In most cases, the original document would be a paper document (expense report and receipts, accountable advance request, bank deposit slip, etc.).
If a department chooses to scan* a financial source document, the scanned version of the source document is referred to as the “access copy”, and currently can only used for ease of reference internally by the department and by the Financial Services Department. The original paper document will continue to be required for audit and verification purposes and therefore the original paper document must continue to be retained / archived / destroyed in accordance with the U of T File Plan. For an explanation of the issues surrounding this policy, see the section Why are original paper documents still required when a scanned copy is available?
* AMS has documented a procedure whereby scanned documents can be “attached” to the transaction document number within FIS (see the AMS document Electronic Imaging and SAP Document Attachments for instructions on how to do this).
Why are original paper documents still required when a scanned copy is available?
In order to be able to destroy original paper documents after scanning these documents, the University would need written confirmation from all our research sponsors as well as from our external auditors. At this time we do not have these required written confirmations.
In the absence of these written confirmations, and if a department were to destroy the original paper documents, the University would be open to a high level of risk with respect to our external audit as well as compromising our ability to obtain future funding from current and prospective granting agencies.
Obtaining such confirmations would require demonstrating that there is an institution-wide process for scanning documents, such that the process can guarantee that the scanned image is the exact, unmodified copy of the original paper document.
Specifically, these confirmations would indicate satisfaction that the University has the following:
- There is an institutional policy on document imaging in place (this policy);
- The University is in compliance with the Canadian General Standard Board Guideline on this subject (CAN/CGSB-72.11-93 Microfilm and Electronic Images as Documentary Evidence). This would entail the establishment of procedures to ensure that the imaging process preserves accurate images of the original records (including signature or other written or graphic images) and that the imaging process is reliable and secure so as to maintain the integrity of the records;
- Certification by our external auditors;
- Management letter confirming our document recordkeeping and retention practices (the U of T File Plan).
At the University of Toronto, we are a decentralized organization where departments have responsibilities for entering most financial transactions and retaining original financial documents. Many departments are relatively small and may not have the resources to properly abide by the stringent requirements surrounding CGSB guideline 72.11-93 and subsequently certification by external auditors.
When will approval to destroy original paper documents be given?
The University has initiated discussions with our external auditors, granting agencies and the federal and provincial auditors to determine specific requirements in this area. Once we are able to obtain some definitive guidance, we will let departments know what specific controls, processes and procedures would be required to be put in place in order to eliminate the need to continue to maintain the original paper document. In the meantime, departments are required to maintain the original paper documents in accordance with the U of T File Plan.
Last revision: May 31, 2006