Signatures – the rules
- The learner must confirm the information is correct when it is collected. You must have evidence of this, which can include electronic formats.
- We accept electronic evidence, including electronic/digital signatures. Where evidence is electronic, you must have wider systems and processes in place to assure you that learners exist and are eligible for funding.
- Both electronic and digital signatures are acceptable, we do not specify which should be used, only that a secure process to obtain and store signatures is followed:
- An electronic signature is defined as any electronic symbol or process that is associated with any record or document where there is an intention to sign the document by any party involved. An electronic signature can be anything from a check box to a signature and/or
- A digital signature is where a document with an electronic signature is secured by a process making it non-refutable. It’s a digital fingerprint which captures the act of signing by applying security to a document. Usually documents which have a digital signature embedded are extremely secure and cannot be accessed or amended easily.
- Where an electronic or digital signature is being held, from any party for any reason, you must ensure it is non-refutable. This includes the definitions of both wet and dry signatures. Systems and processes must be in place to assure to us the original signature has not been altered. Where any document needs to be renewed, and a new signature taken, it must be clear from when the new document takes effect, and both must be held.
- You must keep effective and reliable evidence. You are responsible for making the evidence you hold easily available to us when we need it.
(Paragraphs 134-138, ESFA AEB Funding Rules 2020/21)
Signatures – HoW College
We have begun issuing the forms for 2020/21 delivery, and wherever possible, these are being produced in a ‘digital’ format i.e. they can be printed as normal, but they also allow for completion ‘on-screen’ using computers, tablets etc. These are in Adobe PDF format.
They will include the usual spaces for signatures. Until there is a settled and widely available standard for truly electronic signatures, we will generally use text boxes – these allow the individual to type in their name. On the AEB enrolment form, there is also a requirement for them to indicate that this is a digital enrolment via a tick box next to a confirmatory statement. It also indicates that we may request further conformation at a later stage.
Good practice suggests that a separate email from the learner confirming they have completed the enrolment form would be useful. You could combine this email with the first ‘register’ of learning confirmation as discussed below.
Some computers and tablets allow the user to ‘sign’ using a stylus, Apple Pencil etc – these are also acceptable.
When collecting completed forms, please be aware of privacy requirements and GDPR – ’normal’ emails with attachments are generally unsecure. Sending attachments to the College can be easily done by either encrypting and password protecting each document (using for example, WinZip (https://www.winzip.com/mac/en/) or 7Zip (https://www.7-zip.org) and notifying us of the password separately. You can also use our secure DropOff service (https://dropoff.howcollege.ac.uk).
Training providers can also use DropOff for their own services – it is a free service installable on your own servers available from https://zend.to
Evidencing virtual and blended learning
You must be able to evidence participation in learning, whether face-to-face or virtual. Face-to-face is obviously easier (using registers that are signed for example), but virtual learning is slightly more problematic.
Some virtual learning tools allow for the collection of evidence – for example, if you use Microsoft Teams, the ‘meeting’ organiser can download ‘registers’ which show when a person entered and left the meeting (https://docs.microsoft.com/en-us/microsoftteams/teams-analytics-and-reports/meeting-attendance-report). For Google Classroom users, an add-in has been developed (https://gsuite.google.com/marketplace/app/classroom_attendance_tracker/993028068285).
Some may wish to record sessions delivered online – again you need to be aware of privacy concerns particularly when using face videos. Good practice may be to ‘call’ a register online once you have started by asking the participants to say their names (with no cameras on – audio only) and record that portion only.
A ‘belt and braces’ approach would be to ask learners to confirm their attendance – for example, where multiple sessions are delivered in a week, you could list the dates and times for each, and ask them to confirm via email. You could also do the same for telephone support provided, and utilise the email confirmation for other purposes too, making the email itself a tool of support (additional materials offered, links etc.)
Moodle and other online platforms will have their own tools for ‘recording’ attendance which can be utilised.