Purpose:

The Canada Evidence Act allows electronic documents to be submitted to a court of law based on the integrity of the system that produces them.  This policy is meant to provide a framework to support the integrity of the University of Regina’s document imaging system.  Proper and regular disposal of source records after imaging ensures the legitimacy and credibility of the document imaging program.   The Introduction to MEIDE  (Microfilm and Electronic Images as Documentary Evidence) Canadian General Standards Board, CAN/CGSB – 72.11 - 93 states, “To allow source records to continue to exist after imaging is to risk an inference that the images are not as reliable, secure or accurate as the source records.”

• Before this policy is followed it should be weighed carefully whether documents could conceivably be needed as documentary evidence in a court of law to defend or prosecute.   The procedure manuals and logbooks (discussed in this policy) are kept to ensure admissibility of documents in court once the original paper copy is disposed.  If it is very unlikely the document will ever be needed in a court of law, it is unrealistic to prepare a procedure manual and maintain a logbook.  In such cases, deviance from this policy is permitted.  In all cases, unless there are other applicable legal requirements, source documents should be disposed of once scanned. 

Relevant Acts and Standards:

The following Acts and Standards have to be complied with when an electronic image is retained in place of the hard copy document.

• Canada Evidence Act [Section 31.1 to 31.8]
• Personal Information Protection and Electronic Documents Act [Part II]
• The Saskatchewan Evidence Act [Section 29.1(1) to 29.6]
• The Electronic Information and Documents Act, 2000 (Saskatchewan)
• Microfilm and Electronic Images as Documentary Evidence (MEIDE), Canadian General Standards Board, CAN/CGSB – 72.11 – 93
• Books and Records Retention/Destruction, Canada Revenue Agency, IC78-10R3

Policy:

The University of Regina shall image documents specified in this policy “in the usual and ordinary course of business”.  [MEIDE – PART III 1.1] The image will be the official copy for these documents.  All documents being imaged (with disposal of original documents) by the University must be authorized through this policy. [MEIDE – PART III 3.4]

Responsibility:

Responsibility for imaging management system is delegated to these defined “imaging management areas”.  [MEIDE – PART III 1.2]  This list is not meant to be complete.  Further imaging management areas, along with a responsible position, may be identified later.

Imaging Management Area	Position Responsible
Financial Services	Financial Analyst

It is the responsibility of each imaging management area to ensure that this policy is followed for each document being imaged in their area.  The responsible person must create and maintain an up-to-date procedure manual as outlined in this policy for each type of document being imaged.  (See the “Procedure Manual” section for details.)

Certain types of documents may have other legislation or regulations that govern document retention or imaging.  Such legislation or regulation takes precedence over this policy.  It is the responsibility of each imaging management area to ensure all applicable legislation is followed.

Information Services is responsible for ensuring:

• Images, indexes and other data about the images are kept in secure storage.  [MEIDE – PART III 3.5]
• Procedures are in place for backup and recovery of images, indexes and other data. [MEIDE – PART IV 3.4]
• There is an organized system for purging documents from the imaging management system once documentation retention term expires.  This would be done at the advice of the document management area keeping the document.

Authorized Software:

Each imaging management software system keeps its own index of images along with other biographical information such as the person scanning the image, the date scanned, and description of the image.  As a result each imaging management software package must be evaluated against the controls outlined in the “Relevant Acts and Standards” section in this policy and must go through the same approval process as this policy to be authorized for use.  Approved imaging management software systems include:

• Nolij

Procedure Manual:

This policy only outlines the basic points the procedure manual must cover.  [MEIDE – PART III 1 through 4]  Each imaging management area can fully customize the procedure manual for each type of document as long as each of the following points is covered.

1)       Procedures for capturing images that ensure all documents that are supposed to be imaged are imaged. 

2)       Procedures for accurately and completely indexing the images to the BANNER database within a reasonable time frame.

3)       Procedures for checking the quality of each image to make sure the information is readable and that it is an acceptable copy of the original.

4)       The procedure manual should define a select group of people who have complete access to scan, edit and delete images (for retakes). 

5)       The procedure manual should define another group who can have access to view the image but not edit or alter it in any way.

6)       The procedure manual should define another group who are authorized to dispose the original documents.

7)       A log book needs to be kept showing:

·         Description of the documents imaged (e.g., document number),

·         Signature of person imaging

·         Date imaged

·         Signature of person authorizing imaging

·         Date source document was destroyed

·         Signature of person disposing source document

·         Date the digital image is purged, and signature of person authorizing the purge.

Nolij captures the first three bulleted items automatically.  A Microsoft Access report can be used to print out this information regularly.  The other items can easily be captured on the report manually.

8)       Procedures to ensure disposal of source record does not occur before the image is captured, indexed to BANNER, and checked to make sure the image quality is acceptable. 

9)       Source document disposal should occur in a reasonable and regular time frame.

Document Types:

The standards used to formulate this policy did not detail how to determine document types, but each document type will need a procedure manual.  The procedure manual is one of the key supports in proving integrity of the document imaging system, so it should reflect the different documents within an imaging management area as closely as possible. 

In defining document types, the following principles should be used:

• What workflow does the document have?  Documents with similar workflows might be easily combined under one document type (and one procedure manual).  If the same people are scanning the document, entering the data, indexing to BANNER, doing the quality control check and destroying the paper copy such documents might be combined under one document type.
• Who will have complete authorization to create/edit/delete the image?  Who will only have viewing rights?  The policy manual must also specify the groups of users with each type of authorization.  Documents with similar authorization groups might be combined under one document type.

This policy gives the authority for the following documents to be imaged by the University’s imaging management system: [MEIDE PART III 3.4]

Imaging Management Area	Document	Start Date
Financial Services	Invoices and Reimbursement Claims	May 1, 2005
Financial Services	Journal Vouchers, Internal Transfers and Bookstore Charges	May 1, 2006

Changes to this Policy:

The schedule of document management areas, along with the related position responsible, and the schedule of document types authorized for imaging can be updated / changed by any of the imaging management areas (for their respective area).  All other changes to this policy must go to the Vice-President (Administration) for approval.