CAUBO

1
CAUBO

• Imaging Document Management Workflow
• June 26, 2007 - Charlottetown, P.E.I.

2
Panelists

• Germain Tremblay, Director Finance Awards
  Administration, NSERC/SSHRC
• Ken Chasse, Barrister Solicitor - eVida Group
• Mary Anne Rait, System Administrator, Financial
  Services, Ryerson University
• Peter Gee, Assistant Director, Financial
  Services,
• Ryerson University

3
AGENDA

• Introductions
• Ryerson Journey (Gee)
• Imaging System Overview Demonstration (Rait)
• Document Management and Workflows - NSERC SSHRC
  Comments (Tremblay)
• Imaging Electronic Records The Legal Issues
  (Chasse)

4
Background - Whats Happening?

• 1980 - European Commission predicted that by Year
  2000, 50 of all business documents would be
  delivered electronically
• YES - For memos informal communications.
• NO - For financial documents.

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Background - Purchase to Pay (P2P)

• Despite increasing interest adoption of
  solutions to automate Purchasing, AP AR
  processes, enterprises of all sizes are burdened
  by PAPER.
• Institute of Accounts Payable Professionals
  (IAPP) - on average 13 of invoices received are
  electronic.
• Gartner Research
• 90 of invoices are paper based.
• 80 of B2B payments in North America are made by
  cheque.

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Background - AP Benchmarking

• Average AP Department in a 1 Billion Company
• Corrects 5 of supplier invoices because of
  errors,
• Has 12 FT staff for every manager,
• Utilizes 2 applications/systems for AP,
• Uses WEB technology primarily for Requisitioning,
• Processes 250,000 invoices annually,
• Average time to process an invoice is 12 days,
• 1 in 5 invoices has a problem that delays
  processing and increases administrative costs
  (can be 50),
• 25 of invoices are paid late.

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Basic Truism

• Less paper and more e-invoicing is a
  characteristic of a world class company (Hackett
  Value Grid)
• Why ?? Electronic workflow for invoice review
  and approval provides
• Access to timely and accurate financial
  information
• Cost savings
• Improved vendor relationships
• Asked which medium they trusted more, 52 of AP
  departments thought electronic data was likely
  more reliable. This is a judgment on the ease of
  processing

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Demand for P2P AutomationSource 2007 Institute
of Management Administration (IOMA) AP
Benchmark Study

• 41 of AP departments planning to add e-invoicing
  capabilities in 2007 Doubles since 2005
• Over 70 of companies already use e-payments or
  are planning to use them in 2007. However less
  than 25 of all B2B invoices are paid
  electronically.
• 36 plan to add invoice imaging

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Initiatives to Eliminate Paper

• EDI moderately successful in industries where
  they are used to exchanging invoice and purchase
  order data. Lack of standards and cost of
  participation have hindered wider adoption.
• Purchasing Card Programs VERY successful for
  petty cash type transactions as is usually
  limited to transactions below 1500 because of
  post. Invoice data from vendors is often lacking.
• Document Management and Workflow

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Invoice Imaging The Reality

• Imaging and Workflow now seen as the most useful
  technologies (Hackett Group - 2005)
• NO silver bullet - imaging technology does not
  instantly get rid of the paper need to consider
  business process.
• OCR is a technology that captures invoice data
  with reduced manual correction. Then you can
• Validate data against information already in the
  ERP
• Automatically scrub the data with identifiable
  problems like missing/wrong PO number.
• Deliver cleansed data to the ERP for scheduled
  payment processing
• Deliver images to archives for referencing

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Ryerson University

• Students
• 23,000 full time,
• 1000 graduate students
• 65,000 continuing education registrations
• Financial Systems
• Financial Oracle eBusiness V11.5.10,
• Document Management 170 Systems Markview V5.5,
• Other Systems
• PeopleSoft - Student Administration
• Ruffalo Cody Alumni Fundraising
• Highline - Human Resources/Payroll

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Audit and Acceptance Issues

• Requirements for retention of original documents
  is established federally by CRA, provincially by
  Ministry of Finance and internally by Records
  Management (Archives) policy
• In Canada, Ontario and numerous other provinces
  there is already a number of precedences and
  regulatory bills/interpretations that exist as it
  pertains to imaging.
• REAL ISSUE - Acceptance of imaging concept is not
  standardized across all levels of federal and
  provincial government and agencies. Has not
  really been considered by many ministries and
  agencies.
• Corporate - Seek internal corporate approvals
  for approach, then establish policy, procedures
  and compliance standards and GO FORWARD date of
  new policy.

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Overview of Ryerson Timelines

• 170 Systems Contract Signed - April 30, 2004
• 170 System Development May to September 2004
• System walk through September 2004
• TEST Install September 2004
• Preliminary UAT Testing October 2004
• User Training October/November 2004 (ongoing)
• Final UAT Testing November 2004
• TEST Migration to Development November 2004
• Production GO LIVE - December 06, 2004
• Destruction Research November 2004
• Attempts to obtain Formal Acceptance Approvals
  February 2005
• Markview System Upgrade - November 2006
• eVida Certificate of Compliance - December 2006
• Destruction of Originals scheduled for June 15,
  2007

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Acceptance of Imaged Documents

• Basic Principle
• If the original paper documentation still exists,
  then electronic document images are merely copies
• Catalyst
• Tri-Council grant review occurred at same time as
  Imaging Go LIVE.
• CIDA grant monitoring visit (Feb 2005),
• Initial reactions indicated some audit
  discomfort. Recognized better further explore
  these uncharted waters.
• Chose key agencies to obtain written acceptance -
  NSERC, SSHRC, CHIR, CIDA, AUCC, HRSDC, CFI, MEDT

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Acceptance of Imaged Documents

• Dilemma
• A negative response from any single organization
  could effectively negate the positive responses
  received from others by effectively not allowing
  the University to fully introduce and leverage
  the imaging capabilities.
• Manuel of Good Practices (November 2003)
• NSERC, SSHRC, CAS (Common Administrative Service)
• Section 2.3 of manual referenced
• Digitizing of Vouchers - UQAM
• Digitization of Invoices for Authorization
  University of Victoria

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Existing Canadian InitiativesUQAM Approach

• Additional space (and boxes) was needed to store
  vouchers for the 7 years required under federal
  legislation.
• Process was cumbersome - introduced digitization
  to retain copies of vouchers.
• UQAM obtained necessary authorization from
  provincial and federal governments.
• AFTER - Once vouchers verified and payment
  authorized, digitize each voucher and save for
  future consultation and/or printing.

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Existing Canadian Initiatives University of
Victoria Approach

• BEFORE - AP digitize invoices received and send
  digitized invoice by e-mail to person placing the
  order.
• Individual views invoice on screen, ensures it
  matches goods or services received. Account
  holder authorizes invoice payment by returning
  invoice to AP by e-mail.
• Process ensures the recipient actually receives
  the invoice for authorization, the e-mail being
  proof, and makes it easy to send reminders to
  those who forget to authorize the payment.

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Compliance Requirements Compilation of Responses

• Certification by an independent organization that
  the Ryerson Document Management Imaging system
  complies with Canadian General standards Board
  (CGSB) standards
• CGSB 72.11-2000 - Microfilm and Electronic Images
  as Documentary Evidence,
• CAN/CGSB 72.34-2005 - Electronic Records as
  Documentary Evidence.
• Certificate of Image Authorization statement
  from senior management that university relies
  upon electronic record keeping in the usual and
  ordinary course of business.
• Imaging Policy - Electronic Imaging and Document
  Management (May 17, 2006) approved and issued in
  accordance with university policy.
• Imaging Procedure manual - Formal procedure
  entitled Electronic Images Procedure draft was
  August 2, 2006. eVida suggestions were
  incorporated into Final approved procedures.

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Elements of Compliance

• Management Authorization Accountability
• Usual ordinary course of business
• Approval by senior management
• Documentation
• Sufficiently detailed procedures manual
• Evident to all parties and followed
  communication, training
• Reliability
• Authenticity (of records documents)
• Integrity (of the electronic system)

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Compliance Report Requirementss

• Ryerson Wanted
• Independent organization to verify compliance
  with CGSB eVida Group.
• Organization that understood records management,
  the legal issues as it pertains to document
  imaging AND assigned individuals with impeccable
  qualifications and credentials.
• Formal Letter of Compliance.
• Detailed report with GAP analysis and
  recommendations on areas that MUST be
  strengthened.

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Compliance Report Results

• EVida report contained
• eVida Letter of Compliance - statement that
  Ryersons process of converting financial records
  under the 170 Systems Markview product met
  national standards
• CGSB 72.11-2000 - Microfilm and Electronic Images
  as Documentary Evidence.
• CGSB 72.34-2005 - Electronic Records as
  Documentary Evidence
• Certification statement that analysis was made in
  comparison with the National Standards of Canada
  (CGSB standards). The current system was
  examined with a view to converting paper records
  to electronic images, and maintaining all
  electronic images and associated bibliographic
  and biographical records, as authentic, reliable
  and accurate records.
• Detailed analysis report (as of October 31, 2006)
  with specific areas requiring attention in both
  our electronic and paper records. Provided
  recommendations that could further help in
  maintenance of our process to meet the
  evidentiary process on the management of records.

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Compliance Report (eVida Group)

• All conversions from paper to images since
  inception of the 170 MarkView System subjected to
  a quality assurance program to verify the
  acceptable quality of images and recording data
  in accordance with the requirements of the CGSB
  national standards.
• For converted paper records, such proof would
  include evidence that the electronic records have
  reliably captured their source records. This
  permits the university to maintain only one set
  of records (electronic) as the primary source of
  information and evidence, and allow disposal of
  paper records once fully captured by the 170
  MarkView System.
• IT audit policy to include examination of
  electronic records as per national standards as a
  further enforcement of control over the
  management of records. Introduce audit functions
  to supplement internal quality assurance
  procedures to verify process is conducted as per
  university policy and procedures.
• Records Management (Archive) policies should be
  altered to reflect new electronic records
  management practices.
• Key documents (Policy Procedures) needs to be
  in place to demonstrate the electronic record
  system integrity, authenticity of the records,
  and trustworthiness of your process.
• Scanning operators, AP and other document process
  review staff trained in regards to system
  integrity requirements of management records.

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Canadian General Standards Board (CGSB)

• CGSB - 10 Points of Evidence
• Judging the Integrity of an Electronic Records
  system.
• Handout

24
Ryerson Documentation that Supported the
Recommendation for Destruction of Documents

• Electronic Imaging Certification
  Recommendations (March 2007 -Gee)
• Aird Berlis Legal Opinion Legality,
  Enforceability Admissibility of Imaged
  documents (June 2005 Brooks
• eVida Group Certification of Compliance with
  National Standards of Canada (December 2006)
• Electronic Records as Audit Evidence memo
  Richard C. Kennedy, A/Chief Internal Auditor
  Asst. Deputy Minister, Ontario (March 2007),

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Overview of Support Documentation for the
Recommendation for Destruction of Documents

• Continued
• eVida Group - Review of Ryerson Financial Record
  Certification of Compliance on eRecords of
  Financial system (Mark View) measured against
  CGSB Standards,
• eVida Group - Consultant Biographical
  Qualifications,
• Imaging Policy
• Imaging Procedures manual
• Certificate of Image authorization by senior
  Management- usual ordinary course of
  business.
• IN PROCESS Alignment of Records Management
  Archives policy

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Statutory Legal References

• Canada Revenue Agency (CRA) Keeping Records
  (Canada - RC4409),
• Books Records Retention/Destruction (Canada
  IC78-10R3),
• CGSB 72-11-93 Microfilm Electronic Images as
  Documentary Evidence
• CGSB 72-34-2005 Electronic Records as Documentary
  Evidence
• Personal Information Protection Electronic
  Documents Act (PIPEDA Canada Bill C6)
• Evidence Act (Ontario)
• Canada Evidence Act (Canada)
• Electronic Commerce Act (Ontario Bill 88 2000)
• Records disposition Authority No. 96/023
  Records Relating to Electronic Imaging,
• Archives Ontario Information Bulletin 6
  Electronic Records systems Recorded Information
  Management (RIM) Requirements.

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Imaging SystemOverview Demonstration Mary
Anne Rait
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Ryerson MarkView Solution

• Accounts Payable workflows to handle
• Non PO Invoice Entry invoices received with no
  quoted PO
• PO Invoice Entry
• Pre-Approved Invoice invoice received in
  Financial Services previously manually authorized
• Previously Entered rush invoices
• Invoice Gateway decentralized entry process
  which is validated before imported into Financial
  System
• Internet Expense online expense submission

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Ryerson MarkView Solution

• Accounts Receivable Purchasing
• Automated creation of virtual (or rendered)
  invoices and automatic faxing and e-mail
  capabilities
• Creation of document sets attaching supporting
  documentation and identification of documents
  that must be sent to the customer/supplier
• General Ledger
• Ability to attached scanned documents to an
  actual, budget or encumbrance journals
• Ability to associate an image that previously
  exists within 170 MarkView to an actual, budget
  or encumbrance journals

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Ryerson MarkView Solution

• Records Management
• To scan, index, and search documents not
  associated with Oracle Transactions, including
  Insurance, Financial Reports, Contracts,
  Completed Forms, Budget documents

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Benefits on Imaging

• Quicker More Efficient Document Processing
• Easy Universal Access
• E-Mail Notifications
• User To Do Lists (Web Inbox)
• Reassignment of Responsibility when users go on
  vacation/sabbatical etc

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Benefits Contd

• Enhanced Loss Prevention
• Enhanced Security
• Central Electronic Storage, Reduced Filing, Space
  Equipment Needs
• Time Saving
• Enhanced document tracking through the use of
  workflow

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Benefits Contd

• Queue monitoring - Graphic detail,
• Tightly integrated - Oracle eBusiness suite,
• Audit reports Quality Verification queues,
• Simplifies year end accruals.

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Security

• Drilldown from Oracle GL is limited to only those
  documents that the user can view from their
  responsibilities.
• User have no access to inquiry from Payables or
  Receivable modules.
• Documents scanned in are always maintained in
  Markview.
• Recycle queue maintains a history of documents
  that were deemed to be duplicates or not
  required.

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Challenges

• Upfront effort required to ensure scope of
  project is as complete as possible, leave nothing
  to assumptions.
• Communication communicate well in advance to
  Users AND continue to update users with changes
  to processes.
• Know your Users identify the various key Users
  with regards to skill set and previous experience
  with organizational systems
• Processes review and modify processes.
  Document and communicate changes.
• Approvals and compliance with standards in order
  to destroy original paper documents.

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DEMO I

• AP entry and linking of record to image

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Demo II

• Document tracking capabilities

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Document Management and Workflows CAUBO
Conference June 26, 2007

• Germain Tremblay, Director, Finance and Awards
  Administration Division, NSERC/SSHRC

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Outline

• Expectations Imaging
• Control Framework
• Authorization
• Supporting Documentation
• Verification
• Retention

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Agencies Requirements

• Whether a process is paper based or electronic,
  agencies have a number of requirements regarding
  the management of research funding as specified
  in the
• Memorandum of Understanding (MOU) and
• Tri-Agency Financial Administration Guide.

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Imaging

• Agencies expectations in terms of imaging
  practices
• Follow industry standards
• CGSB
• Scanning should be part of usual and ordinary
  activities of the business
• A control system and procedures are established
  and documented and
• Images are of acceptable quality and are legible.

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Imaging

• A system of inspection and quality control is
  established.
• Ensure that adequate controls are in place that
  safeguard the accuracy, security and integrity of
  the data
• Access controls
• Input and output controls and
• Tampering controls.
• Electronic records must provide a proper trail
  from the source document (whether paper or
  electronic) to the summarized financial accounts.

Source CRA, IC05-1 on Electronic Record Keeping,
June 2005
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Control Framework

• As outlined in the MOU, the institution should
  have in place
• policies and procedures
• roles and responsibilities defined
• procedures established and documented and
• A framework approved by a governing board.

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Control Framework

• A good control framework will ensure that
• all expenses are authorized by the PI, or his or
  her delegate
• delegation of spending authority is done in
  writing (must be kept on file and verified) and
• In addition, for travel expenses
• One over one approval

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Control Framework

• Supporting document requirements
• Original documentation must be kept in support of
  the expense
• Purchase order, invoice, hiring contract, JV,
  travel claims, original receipts, etc.
• Missing receipts should be documented and
  approved by the PI.
• Proper documentation in place before expense is
  paid.
• For review purposes, original documentation is
  required.

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Control Framework

• The institution must have a process in place to
  ensure that
• all expenses are reviewed for compliance and
  eligibility (must be someone other than PI)
• the review can be performed before the expense is
  paid, or after and
• the review can be performed on a sampling basis.

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Control Framework

• Document Retention
• Originals must be retained for seven years after
  the expense has occurred.
• Originals should be kept in a central location.

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Imaging and Electronic Records The Legal
IssuesBy Ken Chasse, LL.BBarrister
SolicitorMember of the Law Society of Upper
Canada and Law Society of British ColumbiaCAUBO
Conference, Charlottetown, P.E.IJune 26, 2007
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Industry WatchConfidence Level on Legal
SubmissionSource 2007 AIIM Survey
50

• Validation of Electronic Records Management
  Program with Legal Requirements

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Six Areas of Lawapplicable to Paper and
Electronic Records

• 1. The laws of evidence applicable to electronic
  and paper records
• 2. National Standards of Canada concerning
  electronic records
• 3. The records requirements of government
  agencies, such as the Canada Revenue Agency
• 4. The electronic commerce legislation
• 5. The privacy laws
• 6. The guidelines for electronic discovery in
  legal proceedings.

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Different Types of Records - Different Legal Rules

• Original paper records
• Electronic records, i.e., they are created or
  stored electronically
• Microfilmed or imaged records
• Relied upon printouts of electronic records
  within the meaning of s. 34.1(6) of the Ontario
  Evidence Act, and s. 31.2(2) of the Canada
  Evidence Act, For example
• Records created through EDI (electronic data
  interchange).

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Legal Tests for Acceptable Records

• The integrity of the electronic records system
  
• Relied upon printouts of electronic records
• The usual and ordinary course of business
• The circumstances of the making of the record.

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Compliance Tests for the National Standard of
Canada, Electronic Records As Documentary
Evidence CAN/CGSB-72.34-2005

• Using this national standard to show that a
  records system has the necessary system
  integrity required by the electronic records
  provisions of the Evidence Acts.
• Section 34.1(8) of the Ontario Evidence Act, and
  s. 31.5 of the Canada Evidence Act provide for
  the use of such standards.
• 12 principal groupings of the principles provided
  by this national standard.

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Avoiding the Consequences of Failure to Comply

• An inability to take advantage of the two
  purposes for which the electronic record
  provisions of the Evidence Acts were created
• (a) electronically-produced records are to have
  equal status in law to original paper records
• (b) original paper records can be disposed of
  once their electronic form is stored in a secure
  records management environment.
• A failure to comply with the National Standards
  of Canada (particularly Electronic Records As
  Documentary Evidence CAN/CGSB-72.34-2005) will
  make compliance with the legal tests for
  acceptable records much more difficult.
• Ones records might not be acceptable to the
  taxing authorities of government such as the
  Canada Revenue Agency

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Avoiding the Consequences of Failure to Comply

• (continued)
• The unavailability of essential evidence for
  important litigation.
• An institutions failure to have its records
  accepted as evidence may quickly result in its
  records being challenged in many more legal
  proceedings, which may cripple its ability to
  enforce the legal foundation upon which it
  exists.
• An inability to comply with its own records
  management bylaws or similar policies, with the
  consequences of such failure.
• Being in the embarrassing position of requiring
  records from other institutions and persons that
  comply with the laws and national standards for
  records and information management, but not being
  able to do so oneself.

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Emailthe Electronic Smoking Gun of Casualness

• Email, almost always a casual, informal mode of
  communication, nevertheless creates a record that
  is more often than not a business record, and is
  therefore subject to all laws, policies, and
  procedures applicable to business and government
  records.

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QUESTIONS