Introduction

To increase the efficiency of internal transactions that require authorization, Alexander Paul Institute of Hair Design may require that students and staff use electronic signatures to conduct certain transactions that previously required handwritten signatures and approvals on paper documents.

This regulation establishes the policies and procedures by which Alexander Paul Institute designates school transactions for which e-signatures are required and recognizes and authenticates e-signatures.

This regulation also identifies Alexander Paul Institute requirements for the use of electronic signatures, electronic transactions, and electronic records in conducting Alexander Paul Institute transactions.

Entities Affected

This regulation affects members of Alexander Paul Institute including; students and employees, prospective students and employees, and other individuals who are associated with Alexander Paul Institute, such as affiliates, and associates.

Policies on Electronic Signature Use

A. To the fullest extent permitted by law, Alexander Paul Institute accepts e-signatures as legally binding and equivalent to handwritten signatures to signify an agreement.

B. Students shall use electronic signatures to authorize all designated internal records and transactions. Examples include but are not limited to: Admission forms, Financial Aid forms, accepting financial aid awards, paying student bills, obtaining unofficial transcripts, completing electronic forms, etc.

C. Employees shall use electronic signatures to authorize all designated internal documents. Examples include but are not limited to: viewing personal payroll data, acceptance of handbooks, course catalog, guidebooks, etc; signing off on timesheets, etc.

D. Other members of Alexander Paul Institute, upon mutual agreement with the Institution, may use electronic signatures to conduct designated Alexander Paul Institute transactions and to formally acknowledge their agreement to Alexander Paul Institute transactions; in which they are parties by affixing an e-signature.

E. Alexander Paul Institute right or option to conduct a school transaction on paper or in non-electronic form shall not affect the institutions right, option, or obligation to have documents provided or made available in paper format.

Security Procedures

A. Electronic signatures may be implemented using various methodologies depending on the risks associated with the transaction, and all relevant state, federal, and institution regulations. Examples of transaction risks include: fraud, non-repudiation, and financial loss. The quality and security of the electronic signature method shall be commensurate with the risk and needed assurance of the authenticity of the signer.

B. The e-signature methodology shall be commensurate to the assurances needed for the risks identified. In addition, specifications for recording, documenting, and/or auditing the electronic signature as required for non-repudiation and other legal requirements shall also be determined by the unit.

C. Alexander Paul Institute shall adopt security procedures for e-signatures, e-transactions and e-records that are practical, secure, and balance risk and cost. It is not the intent of this regulation to eliminate all risk, but rather to provide a process for undertaking an appropriate analysis prior to approving the use of e-signatures, e-transactions or e-records for specific institution transactions; and, based on such analysis, to designate those institution transactions in which e-signatures, e-transactions and e-records shall be required in place of handwritten documents.

D. The security requirements for Alexander Paul Institute transactions include, but are not limited to, password policies, secure transmission policies, and federal and state regulations.

Violations and Sanctions

A. It is a violation of this regulation for an individual to sign any Alexander Paul Institute transaction on behalf of another individual, unless he or she has been granted specific authority by that individual.

B. Individuals shall report any suspect or fraudulent activities related to electronic signatures immediately to any manager or supervisor within the institution.

C. Employees who falsify electronic signatures or otherwise violate this regulation are subject to disciplinary action, up to and including termination of employment and criminal prosecution under applicable federal and state laws.

D. Students who falsify electronic signatures or otherwise violate this regulation are subject to disciplinary action under the Honor Code and criminal prosecution under applicable federal and state laws.

E. Other members of Alexander Paul Institute who falsify electronic signatures or otherwise violate this regulation are subject to appropriate sanctions, including but not limited to termination of the relationship and criminal prosecution under applicable federal and state laws.