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2024年7月3日发(作者:)

Guide to Implementing Electronic Signatures

Office of Business and Finance

Office of the Chief Information Officer

Used in conjunction with the Electronic Signature policy

Issued: 09/01/2015

This document outlines the requirements and other important considerations that must be taken into account for units

implementing electronic signatures at Ohio State in compliance with the Electronic Signature policy. Sections include:

− Phasing Out Handwritten Signatures – encourages use of electronic forms and work flows;

− Using the University-Approved Electronic Signature System – describes how to get started with the electronic

signature system;

− Opting Out of Conducting Business Electronically – requirements for handling such requests from employees and

non-employees;

− Transactions in Which Electronic Signatures Should Not Be Used – lists types of transactions that should

continue to use handwritten signatures; and,

− Establishing New Systems with Electronic Signatures – lists requirements for establishing new electronic

signature systems and defines the university-approved authentication method for electronic signatures.

Phasing Out Handwritten Signatures

Not all processes have full online systems built around them. Many processes still require a handwritten signature on a

printed document (forms, contracts, offer letters, etc.). These completed paper documents are then scanned and uploaded

into university transactional systems and/or are stored locally. The university-approved electronic signature system

replaces the need for handwritten signatures. This enables the university to streamline its paper-based processes as either

a short-term solution until a more permanent online system can be implemented, or as a long-term solution.

The key benefit of collecting signatures electronically (as opposed to, e.g., scanning and uploading documents signed by

hand) is time savings. Processes that must wait for someone to return from a trip to sign something or that require

signatures from multiple people will be completed in minutes or hours, instead of days or weeks, using electronic

signatures. With this approach, processes that require input from individuals (e.g., hire data worksheet) collect the

information in typed form, not hand-written form, reducing data entry questions due to illegibility. Electronically signed

documents are already in electronic form (no scanning) and are stored electronically. This makes it easier to share

documents with those who need access to them and it makes it easier to find specific documents since the information

contained therein may be searchable. If a paper copy is ever needed, it is easy to simply print the document.

Units should discontinue using printed versions of documents to gather handwritten signatures, except when handwritten

signatures are required by law (see Transactions in Which Electronic Signatures Should Not Be Used below). Instead,

units should use electronic versions of those documents (Word, PDF, other common formats, etc.) to gather signatures

electronically via the university-approved electronic signature system. Once the electronic signatures are complete, the

resulting electronically signed documents can be uploaded into the appropriate university transactional systems (e.g.,

PeopleSoft HR/SIS/Finance, eRequest, eLeave, HR Action, AdvisingConnect, OSUMyChart, Epic, etc.) and/or stored

electronically as needed.

Using the University-Approved Electronic Signature System

The university approved electronic signature system, DocuSign, enables university employees to send documents to

individuals to sign electronically. All university faculty, staff, and students are automatically set up with the ability

to sign electronically and do not need to take any additional steps to be able to receive documents via the system.

Some university employees may be set up with additional access to the system that enables them to send documents out

for electronic signature. Documents sent via the system can be signed electronically by both university and non-

university individuals. Table 1, below, summarizes the different roles for the system and the process individuals must

follow to gain access.

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Guide to Implementing Electronic Signatures

Office of Business and Finance

Office of the Chief Information Officer

Used in conjunction with the Electronic Signature policy

Issued: 09/01/2015

Table 1: Summary of System Roles and Processes

Role Abilities

Signer Sign documents only

Request and Approval Process

Sender What a signer can do plus send

documents using predefined

forms and templates only

Author What a sender can do plus send

custom/ad hoc documents;

create and share predefined

forms and templates with

senders

Administrator Manage the DocuSign system

and/or integrate DocuSign with

other systems via API (OCIO

only)

Requesting Assistance

Signers needing technical assistance signing a document electronically may contact 8-HELP (*************

), or contact

the unit who sent the document to them originally. Senders and Authors needing assistance should contact 8-HELP who

will immediately route their requests to the OCIO and B&F support teams.

Security and Additional Controls

When used as directed, the university-approved system provides reasonable assurance (1) of the authenticity of electronic

signatures, (2) that the signatures will not be rescinded (the signer cannot make a legitimate or supportable claim they did

not sign it), and (3) of the integrity of the electronically signed records. The proper use of this system also mitigates risks

in cases when the electronic record to be signed contains internal, private, or restricted data as defined by the Institutional

Data policy.

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No request is needed.

University individuals are automatically set up as signers through

the university identity management system and use their name.n

and password to log in and sign documents.

Non-university individuals do not need a login/password to sign a

document sent to them by an Ohio State employee; however, they

may be required to enter a code sent via SMS/Text message or

other method before they are able to sign.

University Employee completes Institutional Data training,

eSignature Overview, and eSignature Sender training. Employee

submits a request via the DocuSign Request Form in

ServiceNow. Access Management confirms training is complete.

Access Management sends request for approval. Senior Fiscal

Officer approves. Access management grants access and informs

employee.

University Employee completes Institutional Data training,

eSignature Overview, eSignature Sender, and eSignature Author

training. Employee submits a request via the DocuSign Request

Form in ServiceNow. Access Management confirms training is

complete. Access Management sends request for approval. Senior

Fiscal Officer approves. Access management grants access and

informs employee.

OCIO employees responsible for managing the DocuSign system

and/or for integrating DocuSign with other systems via its API

request administrator access directly from the Deputy CIO who

approves. OCIO employees must complete both Sender and

Author training plus administrative and, if applicable, API

training before access will be granted.

Training

Required?

No

Yes

Yes

Yes

Guide to Implementing Electronic Signatures

Office of Business and Finance

Office of the Chief Information Officer

Used in conjunction with the Electronic Signature policy

Issued: 09/01/2015

Some additional controls (e.g. a code sent via SMS/Text message in addition to the signature) are required for certain

types of documents and/or certain signature processes. These controls are addressed in detail as part of the Electronic

Signature Sender and Author training. Signers needing technical assistance with these should contact 8-HELP or the unit

that sent the document originally.

Table 2: Summary of Two-Factor Authentication Requirements

Recipient

OSU email account

OSU email account

Type of Data

All data except

restricted

Restricted

Log-in Required

Shib login

Shib login

Two factor

authentication required

No

No

Other Requirements

The author is required

to use the masking

criteria and workflow

the document such that

the input of restricted

data is last in the

workflow when

possible.

Account needs

requested through

OCIO

Account needs

requested through

OCIO

Non-OSU frequent

user (e.g. vendors)

Non-OSU frequent

user

Non-OSU

infrequent user

(e.g. new hire)

All data except

restricted

Restricted

DocuSign login No

DocuSign login Yes

All data N/A Yes

Records Retention

Once a document is complete, the unit must retain the resulting records in accordance with the university Records

Retention Schedule, other university policies (e.g. Personnel Records, Travel, Procurement, etc.) and the Information

Security Standards.

Opting Out of Conducting Business Electronically

As university processes are converted from handwritten signatures to the university-approved electronic signature system,

employees, including student employees, acting within the scope of their employment, are expected to use it and may not

opt out of conducting a transaction electronically. However, if an employee needs an ADA accommodation, handwritten

signatures or other approaches recommended by the university ADA coordinator should be used.

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Guide to Implementing Electronic Signatures

Office of Business and Finance

Office of the Chief Information Officer

Used in conjunction with the Electronic Signature policy

Issued: 09/01/2015

Individuals and entities, excluding employees acting within the scope of their employment, may opt out of conducting a

transaction electronically by providing written notice of the decision to opt out of conducting business with the university

electronically per transaction. The written notice must be directed to the university employee responsible for the business

relationship with the party. In such cases, handwritten signatures or other approaches recommended by the university

ADA coordinator should be used. The notice to opt out should be retained with the record that was signed. Upon receipt

of such notice, the university may reassess its interest in contracting with the party choosing to opt out, and retains the

right to cancel the pending transaction, unless otherwise obligated by law or agreement.

Best practices on how to process requests to opt out are included in the Electronic Signature Sender training. Best

practices on designing ADA accessible electronic signature forms and templates are included in the Electronic Signature

Author training.

Transactions in Which Electronic Signatures Should Not Be Used

Electronic signatures should not be used for the following types of transactions (use a handwritten signature):

• Wills, codicils and testamentary trusts

• Commercial paper, which includes paper checks and promissory notes (ORC §1303; UCC Article 3)

• Documents of title, for example a property deed, automotive title or bill of lading (ORC §1307; UCC Article 7)

• Documents relating to securities, for example a stock certificate (ORC §1308; UCC Article 8)

• Ohio Public Employees Retirement System forms

The above exceptions do not include transactions involving the sale of goods or services or leases (see ORC §§ 1302,

1310; UCC §§ 2, 2A), for which electronic signatures may be used.

The university-approved electronic signature system may not be used to collect credit card numbers.

Establishing New Systems with Electronic Signatures

If a unit wishes to implement a new system with a different method of gathering electronic signatures, or seek to use an

existing or the university-approved electronic signature system with a non-standard configuration, it must apply for

approval by sending a request to *************

. The Business and Finance Senior Director for Shared Services and the

Deputy CIO of the Office of the CIO will evaluate the request and either approve or deny it using the criteria below. To

be approved, the new system must:

1. Employ a university-approved authentication method at the time of signature (see University-Approved

Authentication Method for Electronic Signatures section below);

2. Meet Information Security Standards for electronic records that contain institutional data classified as internal,

private or restricted (see Information Security Framework, /itsecurity/framework

);

3. Use separation of duty and other controls to mitigate risks;

4. Employ the access, monitoring, maintenance, security, and other controls to provide reasonable assurance of the

authenticity of electronic signatures, that the signatures will not be rescinded, and the integrity of the

electronically signed records.

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Guide to Implementing Electronic Signatures

Office of Business and Finance

Office of the Chief Information Officer

Used in conjunction with the Electronic Signature policy

Issued: 09/01/2015

University-Approved Authentication Method for Electronic Signatures

An electronic signature that does not employ a university-approved authentication method at the time of signature may not

be binding on the university and because of this, units must use a university-approved authentication method. A

university-approved authentication method meets all of the requirements outlined in Table 2. The university-approved

electronic signature system meets all of these requirements.

Table 3: Requirements for University-Approved Authentication Method for Electronic Signatures

Requirement

Authenticity

Description

The person signing is who

they say they are.

Method/System

The system must require authentication before enabling the signer to sign

electronically. For university constituents, this authentication will happen

with a user’s university name.n credentials via:

Shibboleth

Other AD/LDAP system if the signer’s user account is automatically

synchronized with Ohio State’s Identity Management System

Signing a PDF file using the “Sign” option in Adobe Reader does not meet

this requirement, nor does just typing one’s name or drawing one’s signature.

Nonrepudiation The signer must take an

affirmative action of some

kind to sign it. The signer

cannot make a legitimate or

supportable claim they did

not sign it.

It is possible to tell if a

completed electronic

signature has been falsified

or tampered with.

Two-factor authentication (a login/password and an additional code given to

the signer by some other means) is required in cases when the signature is on

a record that contains private or restricted data or carries material risk.

Two-factor authentication also mitigates the risks of: a) a record to be signed

being forwarded from the recipient to another individual who could sign as if

they were the original recipient, or b) the email account to which a signature

request is sent being compromised.

Workflow systems (e.g., eRequest) are secured to ISS standards so that

completed signatures cannot be reversed or tampered with. Systems that

produce certificates of signing must make those certificates tamper evident

(e.g., DocuSign’s digitally sealed certificate).

When the signing is complete, the recipient must be capable of retaining the

electronic record in electronic or print form. With DocuSign, this is

accomplished by receipt of a completed PDF once the signing is complete.

Individuals and entities, excluding employees acting within the scope of their

employment, may choose to opt out of conducting a transaction electronically

by providing written notice of a request to opt out of conducting business

with the university electronically. The written notice must be directed to the

university employee responsible for the business relationship with the party.

Integrity

Statutory Electronic records being

Requirement ORC capable of retention by

§1306.07 recipient at time of receipt.

Statutory

Requirement ORC

§1306.04 and

ORC §1306.16

In some cases, it is possible

to opt out of signing

electronically for a particular

transaction.

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