CAUBO
Imaging: Document Management & Workflow
June 26, 2007 - Charlottetown, P.E.I.
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
June 26, 2007
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)
June 26, 2007
Background - What’s 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.
June 26, 2007
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.
Invoicing Methods
• 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.
June 26, 2007
9%
Paper
Electronic
91%
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.
June 26, 2007
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
June 26, 2007
Demand for P2P Automation
Source: 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
June 26, 2007
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
June 26, 2007
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
June 26, 2007
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
June 26, 2007
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.
June 26, 2007
Overview of Ryerson Timelines
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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
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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
June 26, 2007
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
June 26, 2007
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
June 26, 2007
Existing Canadian Initiatives
UQAM 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.
June 26, 2007
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.
June 26, 2007
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.
June 26, 2007
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)
June 26, 2007
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.
June 26, 2007
Compliance Report Results
•
EVida report contained
> eVida Letter of Compliance - statement that Ryerson’s 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.
June 26, 2007
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.
June 26, 2007
Canadian General Standards Board (CGSB)
CGSB - 10 Points of Evidence
Judging the Integrity of an Electronic Records system.
Handout
June 26, 2007
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),
June 26, 2007
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
June 26, 2007
Statutory & Legal References
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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.
June 26, 2007
Imaging System
Overview & Demonstration
Mary Anne Rait
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
June 26, 2007
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
June 26, 2007
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
June 26, 2007
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
June 26, 2007
Benefits Cont’d
• Enhanced Loss Prevention
• Enhanced Security
• Central Electronic Storage, Reduced Filing, Space &
Equipment Needs
• Time Saving
• Enhanced document tracking through the use of
workflow
June 26, 2007
Benefits Cont’d
• Queue monitoring - Graphic & detail,
• Tightly integrated - Oracle eBusiness suite,
• Audit reports & Quality Verification queues,
• Simplifies year end accruals.
June 26, 2007
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.
June 26, 2007
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.
June 26, 2007
DEMO I
AP entry and linking of record to image
June 26, 2007
Demo II
Document tracking capabilities
June 26, 2007
Document Management and
Workflows
CAUBO Conference – June 26, 2007
Germain Tremblay, Director, Finance and Awards
Administration Division, NSERC/SSHRC
June 26, 2007
Outline
Expectations – Imaging
 Control Framework
 Authorization
 Supporting Documentation
 Verification
 Retention

June 26, 2007
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.
June 26, 2007
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.
June 26, 2007
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
June 26, 2007
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.
June 26, 2007
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
June 26, 2007
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.
June 26, 2007
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.
June 26, 2007
Control Framework
Document Retention:

Originals must be retained for seven years after
the expense has occurred.

Originals should be kept in a central location.
June 26, 2007
Imaging and Electronic Records –
The Legal Issues
By:
Ken Chasse, LL.B
Barrister & Solicitor
Member of the Law Society of Upper Canada and
Law Society of British Columbia
CAUBO Conference, Charlottetown, P.E.I
June 26, 2007
Industry Watch
Confidence Level on Legal Submission
Source: 2007 AIIM Survey
How confident are you, that if challenged,
your organization could demonstrate that
your electronic information is accurate,
accessible, and trustworthy?
2006 2007
Very confident
12%
9%
Quite confident
23%
19%
Confident
28%
26%
Slightly confident
22%
27%
Not confident at all
12%
20%
June 26, 2007
Validation of Electronic Records
Management Program with Legal
Requirements
June 26, 2007
Six Areas of Law
applicable 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.
June 26, 2007
Different Types of Records Different Legal Rules
1.
2.
3.
4.
5.
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).
June 26, 2007
Legal Tests for Acceptable Records
1.
“The integrity of the electronic records system;”
2.
“Relied upon printouts” of electronic records;
3.
“The usual and ordinary course of business;”
4.
“The circumstances of the making of the record.”
June 26, 2007
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.
June 26, 2007
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.
•
One’s records might not be acceptable to the taxing authorities of
government such as the Canada Revenue Agency
June 26, 2007
Avoiding the Consequences of
Failure to Comply
(continued)
•
The unavailability of essential evidence for important litigation.
•
An institution’s 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.
June 26, 2007
Email
the 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.
June 26, 2007
QUESTIONS
June 26, 2007