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THE CORPORATION OF THE CITY OF WINDSOR
POLICY
Service Area: Office of the City Solicitor
Policy No.:
Department:
Legal, Real Estate & Risk
Management
Approval Date:
April 19, 2021
Division:
Approved By:
CR 138/2021
Effective Date:
April 19, 2021
Subject:
Electronic Signature Policy
Procedure Ref.:
Review Date: April 2026
Pages:
Replaces:
Prepared By: Kate Tracey
Date:
1. POLICY
1.1. The Corporation of the City of Windsor (the "Corporation") is committed to
streamlining services using the most up to date technology in order to continue
to provide excellent customer service. This Policy and related procedures will
identify types of documents for which electronic signatures will be acceptable
and the manner in which an electronic signature must be provided.
2. PURPOSE
2.1. To provide guidance on when electronic submissions are considered official and
acceptable by the Corporation.
2.2. To adopt a reliable and consistent approach to the use of electronic signatures.
2.3. To expedite workflow processes, modernize records, reduce the need for
physical recordkeeping and improve customer service.
3. SCOPE
3.1. This Policy applies to all Departments, Members of Council and employees of
the Corporation, including Transit Windsor (as approved by Transit Windsor
Board Resolution M104-2015).
3.2. This Policy applies to all documents that are City-owned or created and/or
external documents where execution or sign-offs are required. These include
forms, applications, agreements and correspondence where there is a need for
a signature from the Corporation or an external third party, and only when
statutory or regulatory requirements allow for electronic signatures or electronic
submissions.
3.3. This Policy in no way grants any additional rights or authority on Administration
that have not been delegated by Council, and nothing within this Policy shall be
construed to the contrary.
3.4. All electronic submissions received are subject to the Municipal Freedom of
Information and Protection of Privacy Act, RSO 1990, as amended and Personal
Information Protection and Electronic Documents Act, S.C. 2000, c.5, where
applicable.
4. DEFINITIONS
4.1. Electronic Signature: The Electronic Commerce Act, 2000, S.O. 2000, c.17
(ECA) defines an electronic signature as "electronic information that a person
creates or adopts in order to sign a document and that is in, attached to or
associated with the document." Electronic signatures include but are not limited
to, a typed name at the end of an email, a typed name on an electronic form or
document, an image of a handwritten signature on an electronic submission,
electronic initials when required, a personal identification number (PIN); clicking
"agree" or "disagree", a handwritten but digitally captured signature made on a
touch device, such as a tablet or smartphone.
4.2. Digital Signature: A digital signature is produced by an Electronic Signature
Software, and validates the authenticity of the electronic signature.
4.3. Electronic Signature Software: The software used by the Corporation when
execution or sign-offs of documents are required.
5. RESPONSIBILITY
5.1. The Chief Administrative Officer and the City Clerk are responsible to
contractually bind the Corporation, as delegated by Council.
5.2. The Legal Department is responsible to administer this Policy and answer
questions related to the applicability and legality of using electronic signatures
where necessary.
5.2.1. The Legal Department will be responsible for the review of this Policy
every five (5) years.
5.3. The Information Technology Department is responsible to provide guidance and
support for the approved software to be used by the Corporation in reference to
electronic signatures as well as ensuring the security of any electronic files.
5.4. Executive Directors and Senior Managers are responsible to ensure that staff
are aware of and abide by this Policy and any related procedures.
5.4.1. Executive Directors and Senior Managers are responsible to report any
issues relating to the application of this Policy including electronic security
issues as soon as they are made aware of the situation.
5.4.2. Executive Directors and Senior Managers are responsible to liaise with the
Legal Department in order to determine the situations in which electronic
signatures will be accepted.
5.5. Employees are responsible to ensure they follow this Policy and its related
procedures in all circumstances, and to report any issues that may arise in the
use of an electronic signature to their Executive Director or Department Head.
5.5.1. Employees must only use the methods outlined in this Policy when
accepting electronic signatures.
5.5.2. Employees are responsible to bind the Corporation where delegated by
Council.
6. GOVERNING RULES AND REGULATIONS
6.1. Electronic signatures are not legally binding in all circumstances. The ECA does
not apply to wills and codicils, trusts created by wills or codicils, powers of
attorney, negotiable instruments, and documents of title except for contracts for
carriage of goods. Further, the ECA only applies to electronic signatures
governed by provincial legislation.
6.2. An electronic signature from an external party will not be accepted if it does not
comply with the ECA or other governing law that may be applicable, as
determined by the Legal Department.
6.3. No person shall be compelled or required to use, provide, or accept an
electronic signature without their consent. The Corporation will consent to using
both traditional (ink) signature and/or electronic signature provided by an
external party.
6.4. No person shall represent themselves in a way which is false or misleading
through the transmission of an electronic signature. Where an Executive Director
or Senior Manager believes a misrepresentation has occurred, the signature will
not be accepted.
6.5. Subject to the terms of this Policy, an electronic signature from an external party
utilizing an electronic signature software is acceptable, provided it meets the
Corporation's information technology standards and meets the Corporation's
standards as to method and reliability.
6.6. Subject to the terms of this Policy, when an electronic signature from an external
party is submitted as a scanned counterpart copy of an original signature that is
sent via email, fax, or other electronic means, it is acceptable, provided the
terms and conditions of the agreement allow for signatures to be provided in
counterparts, it meets the Corporation's information technology standards,
meets the Corporation's standards as to method and reliability, and the original
signature is sent to the Corporation by courier or mail in due course.
6.7. Subject to the terms of this Policy, where members of Administration are
required to affix their signature to documents that are City-owned or created
and/or external documents where execution or sign-offs are required, they may
utilize an electronic signature software to do so, provided it meets the
Corporation's information technology standards and meets the Corporation's
standards as to method and reliability.
7. RECORDS, FORMS AND ATTACHMENTS
7.1. Documents generated as a result of this Policy and any related procedures will
be maintained in accordance with the Corporation's Record Retention By-law
subject to any other policy and/or legislation.