Digital Signature Acceptance Policy

1. Overview

See Purpose.

2. Purpose

The purpose of this policy is to guide on when digital signatures are considered accepted means of validating the identity of a signer in eCuras electronic documents and correspondence, and thus a substitute for traditional “wet” signatures, within the organization.  Because communication has become primarily electronic, the goal is to reduce confusion when a digital signature is trusted.

3. Scope

This policy applies to all eCuras employees and affiliates.

This policy applies to all eCuras employees, contractors, and other agents conducting eCuras business with a eCuras-provided digital key pair.  This policy applies only to intra-organization digitally signed documents and correspondence and not to electronic materials sent to or received from non-eCuras affiliated persons or organizations.

4. Policy

A digital signature is an acceptable substitute for a wet signature on any intra-organization document or correspondence, except for those noted on the site of the Chief Financial Officer (CFO) on the organization’s intranet:  <CFO’s Office URL>

The CFO’s office will maintain an organization-wide list of the types of documents and correspondence not covered by this policy.

Digital signatures must apply to individuals only.  Digital signatures for roles, positions, or titles (e.g., the CFO) are not considered valid.

4.1  Responsibilities

Digital signature acceptance requires specific action on both the employee signing the document or correspondence (hereafter the signer) and the employee receiving/reading the document or correspondence (hereafter the recipient).

4.2  Signer Responsibilities

4.2.1        Signers must obtain a signing key pair from eCuras.  This key pair will be generated using eCuras’s Public Key Infrastructure (PKI), and the public key will be signed by the eCuras’s Certificate Authority (CA), <CA Name>.

4.2.2        Signers must sign documents and correspondence using software approved by eCuras IT organization.

4.2.3        Signers must protect their private key and keep it secret.

4.2.4        If a signer believes that the signer’s private key was stolen or otherwise compromised, the signer must contact eCuras Identity Management Group immediately to have the signer’s digital key pair revoked.

4.3  Recipient Responsibilities

4.3.1        Recipients must read documents and correspondence using software approved by eCuras IT department.

4.3.2        Recipients must verify that the signer’s public key was signed by the eCuras’s Certificate Authority (CA), <CA Name>, by viewing the details about the signed key using the software they are using to read the document or correspondence.

4.3.3        If the signer’s digital signature does not appear valid, the recipient must not trust the document’s source or correspondence.

4.3.4        If a recipient believes that a digital signature has been abused, the recipient must report its concern to eCuras Identity Management Group.

5. Policy Compliance

5.1  Compliance Measurement

The Infosec team will verify compliance with this policy through various methods, including but not limited to business tool reports, internal and external audits, and feedback to the policy owner.

5.2  Exceptions

The Infosec team must approve any exception to the policy in advance.

5.3  Non-Compliance

An employee found to have violated this policy may be subject to disciplinary action, up to and including termination of employment.

6. References

Note that these references were used only as guidance in the creation of this policy template.  We highly recommend that you consult with your organization’s legal counsel since there may be federal, state, or local regulations to which you must comply.  Any other PKI-related policies your organization has may also be cited here.

American Bar Association (ABA) Digital Signature Guidelines http://www.abanet.org/scitech/ec/isc/dsgfree.html

Minnesota State Agency Digital Signature Implementation and Use

http://mn.gov/oet/policies-and-standards/business/policy-pages/standard_digital_signature.jsp

Minnesota Electronic Authentication Act https://www.revisor.leg.state.mn.us/statutes/?id=325K&view=chapter -stat.325K.001

City of Albuquerque EMail Encryption / Digital Signature Policy

http://mesa.cabq.gov/policy.nsf/WebApprovedX/4D4D4667D0A7953A87256E7B004F6720?OpenDocument

West Virginia Code §39A-3-2:  Acceptance of electronic signature by governmental entities in satisfaction of signature requirement.   http://law.justia.com/westvirginia/codes/39a/wvc39a-3-2.html

Revised: March 14th, 2018

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