Electronic Signatures & Document Retention

Context

The University of Toronto Finance Division recognizes that a significant amount of university business, and the related communications and exchange of documents, occurs electronically.

The following guideline applies to internal financial documents and includes best practices on the use of electronic signatures and document retention.

Definitions

An Electronic Signature (or E-Signature) is any electronic process that indicates acceptance of an agreement or a record. An electronic signature can include any electronic symbol attached to a contract or other record, used by a person with an intent to sign.

A Digital Signature is a type of Electronic Signature that uses certificate-based digital IDs to authenticate signer identity and demonstrate proof of signing. Digital signatures use specific technology to generate electronic signatures that guarantee that an electronic document, and the person who signs it, are authentic. Validation occurs through trusted certificate authorities (CAs) or trust service providers (TSPs).

An Internal Financial Document is a physical or electronic record of information that is recorded or stored by any means as evidence of the internal approval process for a financial transaction and/or financial reports.

Examples of such documents include:

Cheque Requests
Authorization of Invoices
Expense Report (i.e., Expense Reimbursement)/Accountable Advance Settlement)
Approval of month-end reconciliation and management reports

Outgoing Foreign Payments Wire Transfer Request
Journal Entry (or Internal Revenue / Expense Recovery)
Budget Transfers

Use of Electronic Signatures

Electronic Signatures may be used to indicate the approval of Internal Financial Documents, provided there is clear, auditable evidence of who has performed each action pertaining to the transaction or report review process, and the document can be stored and retained in accordance with the University of Toronto File Plan. Where there are no University or other requirements to use a specific digital signature application, any form of Electronic Signature described below may be used.

Important: Departments/ divisions should consider any legal or other requirements to use original wet signatures and retention of original documents. Where the use of wet signatures or the retention of original paper records is required by law, University policy, or other external regulation or guideline (e.g. external granting agency policy), these requirements take precedence over this guideline.

Acceptable Formats

The University may employ certain tools that are characterized by robust audit trails, advanced features like templates and workflow, and document management capabilities (such as uSOURCE, ServiceNow, and DocuSign). These “gold level” solutions are the preferred form of electronic approval. However, these tools may not be practical or affordable in all instances.

Other acceptable, low-cost options for Electronic Signature include:

Embedded signature image in a document

Using Sign and Fill with Acrobat Reader
Print, sign with wet signature and scan
Acrobat Reader using Digital ID
Acrobat Reader using Stamp
Email with signature block (sent from a University of Toronto email address)

Minimum requirements

With the exception of email (see below), any of the low-cost options listed above are acceptable forms of Electronic Signature when affixed directly on to the approved document.

An Electronic Signature should clearly identify the signatory and indicate their intent in signing the document. The following information should accompany an Electronic Signature:

A statement indicating the intent of the signatory, such as “Approved for payment”, “Approved for posting” or “Reviewed and approved”.
The name, current title, and department of the signatory, and date of signature

Any other information required to process the transaction (e.g. general ledger accounts, funding source, cost allocation, and tax code) that is not already provided on the document

Email approvals

Approvals provided by email with a signature block may be accepted if, in addition to the minimum requirements noted above, the following conditions are met:

The email is sent from a University of Toronto email address (i.e. accessed using your UTORid);
The document(s) being approved are attached to the email (i.e. the approver should re-attach the approved document in their email to the individual processing the transaction);
The email thread contains sufficient information to identify the document/ transaction/report(s) that is being approved (for example, when approving a vendor invoice, the name of the vendor, the invoice number and the amount of the invoice being approved should be included in the email). The information may be provided anywhere in the e-mail trail (i.e. by the requester or the approver)
The signature block of the approver must include their title and department

Example #1:

From: Emily Smith <>
Sent: May 11, 2023 2:08 PM
To: Joe Daniels <>

Joe,

The attached invoice #555 from XYZ Services Co. in the amount of $11,300 is approved for payment.

Thanks.

Emily Smith

<<TITLE>>

<<DEPARTMENT>>

Example #2:

From: Emily Smith <>
Sent: May 11, 2023 2:08 PM
To: Joe Daniels <>;

Approved.

Thanks.

Emily Smith

<<TITLE>>

<<DEPARTMENT>>

From: Joe Daniels <>;
Sent: May 11, 2023 2:08 PM
To: Emily Smith <>

Emily,

Please find attached invoice #555 from XYZ Services Co. in the amount of $11,300. Please approve this invoice for payment.

Thanks.

Joe

<<TITLE>>

<<DEPARTMENT>>

Example #3

From: Joe Daniels <>;
Sent: May 11, 2023 2:30 PM
To: Emily Smith <>

Emily,

The month-end statements and management reports for April 2023 have been reviewed and approved.

Thanks,

Joe

<<TITLE>>

<<DEPARTMENT>>

Document storage and retention

The department (or division) is responsible for retention and orderly and safe storage of the records in its custody and destruction of records, in accordance with the U of T File Plan. If your department requires assistance in developing its own records retention plan, contact UTARMS for further information.

Documents created or received through a University system (e.g., uSOURCE for purchase orders, invoices) where approvals are collected electronically, are considered the official University record. Departments are not required to maintain a record of these transactions in an alternate format or location.

Other Internal Financial Documents which are considered official University records may be retained in electronic form as follows:

SAP – Attached to the relevant document in FIS (preferred for all financial transactions including accounts payable, accounts receivable, journal entries, etc.)
Maintained in a folder on the University network
Maintained in a SharePoint folder

What documents should be stored in SAP

Documents attached in SAP should be limited to those relevant to the transaction. For example, support of payment to a vendor should include:

A valid vendor invoice or cheque requisition
Approval documentation, if not affixed to the invoice, such as the email correspondence or “email thread” (see below).
Purchase order (if applicable)

All documents must be saved as either: PDF, Word, XLS, JPEG, or TIFF to be uploaded into SAP. PDF is preferred. Supporting documentation containing personal or other sensitive information should be redacted or stored in an alternate location as discussed above. Other supporting documentation (i.e. contracts, email correspondence not related to approval) should be filed and maintained in an alternate location in accordance with the University of Toronto File Plan.

Guidelines for retaining email correspondence:

An email thread (i.e. the series of email messages and replies within an email conversation) may be retained as additional evidence of the document’s approval as it establishes a chain of custody of the approved document. Email threads, however, can often contain correspondence that is not relevant to the approval of the document (for example, correspondence with the vendor to clarify elements of their invoice or to correct errors). To ensure transaction records contain only relevant information and to ensure file sizes are minimized for ease of transmission and storage, it is recommended that documents requiring approval be initiated in a new email thread.

Document standards

Electronic documents should be scanned or converted in a manner that they can reliably replace the original hard copy documents. Electronic documents, including scanned copies of original hard copy documents, must be complete (i.e. contain all the information contained in the original), readable, and retained in a supported file format, in order to be considered a reliable replacement of the original document. It is the responsibility of the individual placing the record in the designated storage location to ensure the document meets this standard.

Acceptable file formats include:

PDF (Portable Document Format)

- Recommended file format for text-based records
- Where possible, PDFs should be created as Optical Character Recognition (OCR) scans which allow for text searching, or as non-OCR PDFs which lack text searchability
- PDF files can be compressed when created or saved, and information can be lost during this compression. Users should review their final scanned document to ensure it meets the requirements noted above

TIFF (Tagged Image File Format)

- Standard file format recommended for image-based records
- TIFF files can be large so consideration should be given to space limitations when using this format

JPEG (Joint Photographic Experts Group)

- standard file format used for storing scanned image-based records
- JPEG images may experience a loss of quality using smaller file size. Users should review their final scanned image to ensure it meets the requirements noted above

Minimum resolution for electronic documents is 300 dpi (200 dpi may be acceptable for text only, black and white documents).

E-Signature Training Guide

E-Signature FAQ

Last updated January 29, 2024