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Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: 08/12/11




JISC Final Report




Project Information
Project Identifier               SWANI
Project Title                    Secure Work-based         learning   Administration   through   Networked
                                 Infrastructure
Project Hashtag                  #swani
Start Date                       January 2011                   End Date     December 2011
Lead Institution                 Coleg Sir Gâr
Project Director                 Dave Howells
Project Manager                  Prof Tony Toole
Contact email                    dave.howells@colegsirgar.ac.uk
Partner Institutions             n/a
Project Web URL                  https://sites.google.com/site/jiscswani/
Programme Name                   Learning and Teaching Innovation Grants (SWaNI FE) 10/10
Programme Manager                Robin Englebright


Document Information
Author(s)                        Tony Toole
Project Role(s)                  Project Manager
Date                             20/11/2011               Filename          swani_finalreport_v2.docx
URL                              https://sites.google.com/site/jiscswani/swani_finalreport_v2.docx
Access                           This report is for general dissemination


Document History
Version                Date               Comments
v1                     20/11/2011
v2                     08/12/2011         Update based on comments from JISC Programme Manager
                                          and additional information from the project team and the Welsh
                                          Government regarding compliance with EU regulations.




                                                 Page 1 of 14
Document title: SWANI Final Report v1
Last updated : November 2011
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

Table of Contents
NB : This table of contents ‘auto-populates’ - to update the table of contents – place cursor in the table
of contents, right-click your mouse, click ’update field’, select appropriate option


1     ACKNOWLEDGEMENTS ............................................................................................................................ 3
2     PROJECT SUMMARY ................................................................................................................................. 3
3     MAIN BODY OF REPORT ........................................................................................................................... 3
    3.1      PROJECT OUTPUTS AND OUTCOMES ................................................................................................................ 4
    3.2      HOW DID YOU GO ABOUT ACHIEVING YOUR OUTPUTS / OUTCOMES?...................................................................... 5
    3.3      WHAT DID YOU LEARN? ................................................................................................................................ 9
    3.4      IMMEDIATE IMPACT ................................................................................................................................... 10
    3.5      FUTURE IMPACT ........................................................................................................................................ 10
4     CONCLUSIONS ........................................................................................................................................ 11
5     RECOMMENDATIONS ............................................................................................................................. 11
6     IMPLICATIONS FOR THE FUTURE ............................................................................................................ 12
7     REFERENCES ........................................................................................................................................... 12
8     APPENDICES (OPTIONAL) ....................................................................................................................... 12




Document title: SWANI Final Report v2
Last updated : December 2011
                                                                       Page 2 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

1    Acknowledgements
The SWANI project was funded through the JISC Learning and Teaching Innovation Grant
Programme. The project team would like to thank the Programme Manager, Rob Englebright, and the
programme support team for all their help and guidance during the project period.


2    Project Summary
The SWANI project (Secure Work-based learning Administration through Networked Infrastructure)
had the overall aim of creating an online administrative system for the work-based learning (WBL)
programmes at Coleg Sir Gâr that included a document authentication process that would meet the
requirements of the EU Directive on Electronic Signatures and was also acceptable to the Wales
Assembly Government. A further aim was to deliver a system that was significantly more time-efficient
and cost-effective than the previous paper-based system, as well as enhancing the learning
experience.
The Joomla open source content management application was chosen for the digitisation exercise
and a range of WBL system documents were created that met the needs of the management and
administration process in printed form and the intended efficiencies in digitised form. A significant
efficiency gain was a single entry requirement for all main data fields that then populated all
documents using those fields. This had the added benefit of ensuring data consistency across all
documents.
The SWANI project explored a number of different options regarding digital signatures and the
authentication of documents for audit purposes. The initial plan was to examine the use and
acceptance of digital signatures in other areas of European Commission activity and, where such
signatures were validated for audit purposes, to use those examples in negotiations for acceptance
for the purposes of audit within the work based learning programme. It was accepted at the outset,
however, that in the limited timescale of the project, this negotiation was unlikely to be completed.
An alternative approach was therefore adopted which met both the requirements of the EC and WAG
for physical signatures, and the intention of the project to have a fully digitised administrative and
management system for work based learning. The approach was to use a digital pen which both
physically recorded signatures, whilst at the same time created a digital facsimile of the signature and
added it, together with a time record, to the digitised document.
The documents types that this requirement applies to are all related to audit and administration, not to
the WBL competence evidence. There are up to 20 administration documents in the system but some
are only used once (the learner eligibility form when a new learner joins the scheme, for example),
whilst others might be used two or three times (eg, progress records). Some of the forms may not be
required at all (change of circumstance, learner redundancy etc).
The online record system was completed as planned and the digital pen system was tested with all
the digitised audit forms and shown to work as planned. Discussions were conducted with appropriate
authorities to confirm acceptance of the approach for audit purposes and the project concluded with
plans for a full trial in 2012 to be carried out in parallel with the existing paper based system.


3    Main Body of Report
The existing work based learning programme at Coleg Sir Gâr is paper based. The records of all the
learners’ work are held in files that are routinely transported from the college campuses to the
workplaces and are verified by signatures of the training advisors, the employers and the learners.
Records are kept of learner progress and include periodic reviews. These processes meet the
requirements of the system, both from an academic quality point of view and also for audit purposes.
However, a significant number of the data entry fields in the forms are common and repeated entry of
this data is both time inefficient and invites transcription error. A digitised system therefore, where
common data field entry automatically populates all relevant forms, made complete sense. This was a
key objective of the SWANI project.
A difficulty with the digitisation of the WBL system, however, was the requirement for handwritten
signatures on audit documents. Digital signatures are not currently acceptable for the WBL
Document title: SWANI Final Report v2
Last updated : December 2011
                                             Page 3 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

programme, despite the drive for an EU wide policy on digital signature acceptability. A solution
therefore had to be found if a fully digitised system was to be created.
These considerations defined the aims and objectives of the SWANI project:
The broad aim of the SWANI project was to create a fully online work-based learning management,
administrative and learner support system that met the audit requirements of the EU and the Welsh
Assembly Government. It also aimed to deliver a system that was significantly more time-efficient and
cost-effective, as well as enhancing the learning experience.
The specific objectives of the SWANI project were to:
       Create a fully online management, administrative and learner support system for work-based
       learners;
       Implement a system of applying digital signatures to documents that satisfied the audit
       requirements of the EU and the Welsh Assembly Government;
       Carry out a trial of the online system in parallel with the existing paper-based system to
       evaluate and quantify the benefits;
       Provide a detailed report on the SWANI project outcomes that could be used by other
       institutions in the UK facing similar issues.


3.1    Project Outputs and Outcomes


Output / Outcome Type                   Brief Description and URLs (where applicable)
(e.g. report, publication, software,
knowledge built)
SWANI Project Website                   The SWANI Project website is a repository of all the project
                                        documents and outputs. This includes a record of progress in all
                                        of the Workpackages and includes links to all the deliverables.
                                        The URL is https://sites.google.com/site/jiscswani/
SWANI Project Blog                      The SWANI Project blog was a reflective record of the progress
                                        of the project and provided links to key outputs. The URL is
                                        http://swaniprojectblog.blogspot.com/
SWANI Work Based Learning               The WBL website is based on the Joomla open source content
Website                                 management system application and was a major SWANI
                                        project output. The website URL is
                                        http://vcdemo.co.uk/swani/index.php
Enterprise Architecture WBL             The CSG WBL analysis used Enterprise Architecture modelling
Analysis Report                         to portray the administrative processes. The report can be
                                        viewed at:
                                        https://sites.google.com/site/jiscswani/SWANIEAReport.doc
Digital Signature Enabled Forms         A range of forms were digitally enabled as part of the digital pen
                                        testing programme. These are available for viewing at
                                        https://sites.google.com/site/jiscswani/home/digital-
                                        signatures/signature-enabled-forms
Digital Signature Testing Report        The digital signature system was implemented and tested. It
                                        was shown to work as planned and is now being introduced to
                                        the WBL Training Advisor team. Details are shown at
                                        https://sites.google.com/site/jiscswani/home/digital-
                                        signatures/negotiation-documents
SWANI Project Report                    The final deliverable of the project was the project final report
                                        which summarises the project activities and deliverables. The
                                        report can be downloaded at
                                        https://sites.google.com/site/jiscswani/swani_finalreport_v1.docx

Document title: SWANI Final Report v2
Last updated : December 2011
                                               Page 4 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011



3.2       How did you go about achieving your outputs / outcomes?
The SWANI project set out to develop a fully online administrative and learner support system for the
work-based learning programme at Coleg Sir Gâr. The existing systems are all paper-based for the
reason that the Welsh Assembly Government requires original signatures on all auditable documents,
as does the European Union who partly fund the WBL programme in Wales. The WAG specification
of Evidence Requirements for Funding and Payment states that ‘Electronic signatures on any form and
electronically copied versions are not sufficient for European Union audit purposes and will not be
accepted by the Welsh Assembly Government.’
However, the project team was aware of the ongoing debate in the EU about the use of electronic
                                                                                             1
signatures based on the Directive on a Community Framework for Electronic Signatures that was
originally issued in 1999. This has been developed and revised since that time with the express
intention to: make electronic signatures easier to use and help them become legally recognised within
the Member States. The SWANI project planed to explore further the current legal status and
technologies involved in this development and use the information in the planning for its own technical
implementation. This objective was pursued by the project, but was developed in parallel to another
more pragmatic solution involving the use of digital pens as described later in this report.
There were two main developments to be carried out by the SWANI project:
1. The Online WBL Management and Administrative System
       The online WBL management system was based on the open source content management
       system Joomla. The e-Learning Unit at Coleg Sir Gâr, where the project team was, and includes
       the Web Programmer who built the platform, has considerable experience in the use of the
       Joomla application in the delivery of online distance learning. The main task was the creation of
       digital versions of the current paper documents and presenting them in an intuitive and user-
       friendly way for the users through a Joomla implementation built for that purpose.
2. The Digital Signature System
       The project researched digital signature systems that are in use globally, and evaluated
       applications/products that met the system requirements. This included consideration of the use of
       third party digital signature authentication services that provided cost-effective solutions. It also
       explored the use of digital pens as a potential solution and examined a number of different
       products.
       The top level system requirements included:
                 A system that met the audit requirements of the EU and WAG for the WBL programme in
                 Wales;
                 A system that was simple and easy to use by the signatories (Training Advisors,
                 Employers, Learners);
                 A system that was easily installed/hosted/managed and requires only administrative
                 maintenance;
                 A system that was cost-effective and delivered quantifiable cost savings compared with
                 the paper based system it replaced.
Initial Analysis
The project began with an analysis of the existing paper based administrative, management and audit
systems involved in the WBL programme delivered by Coleg Sir Gâr. This was carried out using
                                                                                               2
Enterprise Architecture modelling and made use of the JISC-CETIS Archi EA modelling application .
This involved interviews with all of the stakeholders involved in the work based learning processes
including the learners, the employers, the training advisors, the auditors the programme management
and external agencies such as the Careers Service.


1
    http://europa.eu/legislation_summaries/information_society/l24118_en.htm
2
    http://archi.cetis.ac.uk/
Document title: SWANI Final Report v2
Last updated : December 2011
                                                        Page 5 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

An evaluation report was produced that included a number of EA mappings and identified the key
actors and business processes involved:




Document title: SWANI Final Report v2
Last updated : December 2011
                                         Page 6 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

This allowed the creation of a plan for the digitisation of all the relevant forms and documents and to
review the associated processes and procedures. For example, the Training Advisor Initial
Assessment Process when a new learner joins the programme:




The Digitisation Process
The project team created a website using the Joomla application with the associated support software
and database. It then constructed digitised versions of all the auditable documents that were used by
                                                                                      3
the work based learning staff to record the progress of learners through the system . A key benefit
arising from this process was that all key data fields, such as names, addresses and other related
information, that were repeated on many of the forms, only had to be entered once. This having been
done, the same data automatically populated the same fields in all the other documents.




3
    http://vcdemo.co.uk/swani/index.php
Document title: SWANI Final Report v2
Last updated : December 2011
                                             Page 7 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

The screenshot shows how a drop-down list of forms is available on the site for all the users to select,
and each of these is available to be completed online according to their accredited status as a
stakeholder. The fact that the forms are all available online, means that the details can be entered
from whatever location, institutional or work based, that is appropriate. This avoids the risk in the
existing paper based system of losing documents that are manually transported between different
                                                                                          4
locations. Further information about the Joomla CMS can be found on the project website .
Digital Signature Systems
The project initially set out to establish a system of electronic signature usage that would be
acceptable to the European Union and to the Welsh Assembly Government. The team identified a
number of examples where such signatures are used for audit purposes and also EU policy
documents that had the express objective of establishing digital signatures as the preferred method of
                                 5
verifying auditable documentation .
 However, it was always accepted that agreement on the use of such a system for the WBL
programme in Wales, although highly desirable, was not achievable in the timescale of the SWANI
project. The project team therefore explored an alternative solution that would satisfy the requirement
for a handwritten signature on all auditable documents, whilst at the same time maintaining a fully
digitised record system. This was through the use of digital pens.
The Digital Pen System
There are a number of commercial digital pen systems that record what is written by the pen and then
download that information to computers running the associated software. The criteria that the SWANI
project applied were that:
          The pens should be wireless, rechargeable and should act as normal pens as well as
          recording digitally what is written;
          The pens should have the capacity to transmit the digitised content remotely to the Joomla
          server where the forms would be automatically updated;
          The handwritten signatures and the forms used to record them satisfied the audit
          requirements of WAG and the EU;
          The cost of the pens and software should be low enough to achieve the overall cost
          efficiencies planned for the digitised system.
                                                                      6
The solution chosen was the Destiny Fastdox product . This met all of the above criteria and the
system is shown diagrammatically below:




4
  https://sites.google.com/site/jiscswani/JoomlaBriefingDocument.docx?attredirects=0
5
  https://sites.google.com/site/jiscswani/home/digital-signatures/negotiation-documents
6
  http://www.destinywireless.com/flash/#/home/intro/
Document title: SWANI Final Report v2
Last updated : December 2011
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Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

The product works by installing the software on the target computer as an additional printer in the list
available when documents are printed. When any of the WBL forms from the drop down list are
selected and the Fastdox printer is selected, the form is printed with a matrix of dots in the
background that are used by the pen to record the position of the pen when it writes on the page.
These digital images are transmitted by Bluetooth via a mobile phone to the host computer where the
form was originally printed. The PDF version of the form held on that computer is automatically
populated with the facsimile of the written content in exactly the same position on the page as the
handwritten version. The digitised version is also time-stamped and any subsequent writing on the
same physical version results in a new updated digital version with its own time stamp.
The original paper version is filed as before for audit purposes, but the digitised version means that
WBL management and administrative staff can gain online access to the information at any time
without having to be in the same place as the file.
The two versions are shown in the example below:




Physical version                                      Digital version


It can be seen that the digitised version is a faithful reproduction of the original. The system has been
trialled by the WBL team and has been evaluated by the Welsh Office WBL auditors. The digitised
system and the use of the digital pen have been approved in principle (see Appendix A) and will move
forward to a full trial in 2012.


3.3    What did you learn?
Evaluation activities
In the evaluation phase of the project the JISC-CETIS Archi Enterprise Architecture tool was used to
model the administrative and management processes. The advantage of using EA modelling
techniques is that it explicitly links the business process layer to the application and technical layers.
This means that, for a technology supported business process improvement project such as SWANI,
a mapping of the business processes to the support infrastructure is easily achieved and portrayed
schematically.


Document title: SWANI Final Report v2
Last updated : December 2011
                                              Page 9 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

The functionality of the Archi tool is excellent, and is particularly supportive of users who are new to
the methodology. The ‘Magic Connector’ relationship option, for example, automatically offers the
options available for relationships between the objects that make up the model being constructed.
The key benefit from using EA modelling was the way it facilitated stakeholder conversations about
how administrative and management processes happened and how changes might improve
effectiveness and efficiency.
Research activities
The research into digital signatures revealed that there were clear precedents for the use of such
signatures in EU audit processes. It is therefore concluded that this is a valid avenue to pursue for the
future of WBL in Wales. The planned parallel trial of the digital system in 2012 will provide a vehicle
for taking those negotiations forward.
The pragmatic solution chosen to meet the objectives of the SWANI project, that of using digital pens,
was successful and provided some useful lessons.
The first was that simple solutions sometimes make more practical sense than pursuing logically
compelling but difficult solutions that rely on high level negotiation. The second lesson was that the
digital pen solution was scalable. It could be implemented at a local level to satisfy the needs of a
particular programme, or it could be implemented at enterprise level and integrated with institutional
MIS systems if that was appropriate.
This is potentially important at Coleg Sir Gâr, for example, as the college operates as a partner in a
WBL consortium in South West Wales and the expectation is that the system would be rolled out on a
much wider scale if the trials are successful and accepted by the other partners.
User testing
The WBL team at Coleg Sir Gâr have been involved in the SWANI project throughout, and this has
included evaluating the digitised version of the paperwork and testing the digital pen system.
However, time did not allow a full trial of the system and this was always planned for the end of the
project and in 2012. The outcomes of that process will be published outside of the reporting for
SWANI.


3.4    Immediate Impact
The immediate impact of the SWANI project will be on the way in which the WBL programme at Coleg
Sir Gâr is managed and the documentation completed. There is still work to be done in completing
digitisation of all the forms, but the major records are available for trials.
All of the work to date has been carried out by the project team and the WBL staff at Coleg Sir Gâr.
The plan is to involve all other partners in the trials in 2012 and the expectation is that they will
participate in the evaluation with a view to implementation on successful completion.
All of the feedback during the project has confirmed that the efficiencies offered by the digitised
administrative system are welcomed by all stakeholders. The EA modelling process had the added
effect of promoting a re-examination of the WBL management processes themselves, particularly the
way they are currently distributed through the Coleg Sir Gâr Faculty structure, with the possibility that
organisational benefits may result in addition to the efficiency benefits.


3.5    Future Impact
The potential future impact of the SWANI project has already been referred to and could be important
at a number of levels. The impact on the institution and the efficiency of its processes is the most
obvious. However, there is a reasonable expectation that it will impact at regional level as the trials go
ahead. Discussions at a national level will also proceed regarding digital signatures for audit purposes
and this may have significant impact on future policy and procedures. The initial feedback from the
Welsh Government confirms the validity of the approach used and that it meets EU audit
requirements.



Document title: SWANI Final Report v2
Last updated : December 2011
                                             Page 10 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

It is hoped that the outcomes of the SWANI project will be of use and benefit to other institutions who
are engaged in similar work based learning programmes. The digitisation of administrative procedures
and documentation is an obvious route to take and the solution to the audit trail requirements may be
of value to others in the education community faced with similar requirements.


4    Conclusions
General conclusions
The general conclusions that the team has drawn from the SWANI project are that:
         Full digitisation of the administrative and management documentation for the work based
         learning programme at Coleg Sir Gâr offers significant efficiencies, operational benefits and
         data security;
         The digitisation can be accomplished using open source solutions, such as Joomla, thus
         adding to the cost efficiencies of the approach;
         The difficulties of meeting EU and WAG requirements for signatures on all audit documents
         can be solved in more than one way;
         The digital pen solution satisfies both the handwritten signature requirement and the plan for
         a fully digitised system;
         The outcomes of the SWANI project will allow Coleg Sir Gâr to achieve its objective of
         implementing a digital administrative and management document system for WBL during
         2012.
Conclusions relevant to the wider community
         The implementation of a digitised audit process that satisfies the requirements of EU
         programmes will be of value to other institutions delivering similar programmes;
         The implementation of an open source document management system may also be of use to
         other institutions looking for similar cost effective solutions;
         The use of Enterprise Architecture modelling is a very effective instrument in business
         planning and the JISC-CETIS Archi tool is an excellent and freely available application for this
         purpose.
Conclusions relevant to JISC
         The immediate conclusion that the project team came to was that the JISC LTIG programme
         was a very effective way of allowing institutions to solve specific TEL issues;
         A related conclusion was that the issues being addressed were very likely to be faced by
         others in the JISC community and that the solutions found would be transferable;
         It was felt important that the success of the Archi tool should be highlighted.


5    Recommendations
General recommendations
It is recommended that:
         The institution and the regional WBL programme partnership complete the parallel trial
         planned for 2012;
         The digital pen system be approved for general use in audit purposes and that negotiations
         continue regarding the approval of digital signatures generally for this purpose;
         The trials in 2012 be used to further refine the digital system for WBL administration and that
         this be approved as the preferred regional approach.
Recommendations for the wider community
         That open source solutions for institutional document management and storage should be a
         serious consideration;
         That Enterprise Architecture modelling is an effective tool in management planning and that
         the JISC-CETIS Archi application is recommended;


Document title: SWANI Final Report v2
Last updated : December 2011
                                             Page 11 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011

         That digital pen technology can be recommended as an effective way of authenticating audit
         documents.
Recommendations for JISC
         That the LTIG programme and other small scale innovation grant initiatives be continued
         (despite difficult financial conditions) as a highly cost effective way of promoting TEL;
         That open source, web 2.0 and cloud computing solutions should be promoted to the
         education community as a cost-effective way of using technology in support of learning.


6    Implications for the future
The implications for the future relate to anyone involved in European funded projects that are
constrained by the audit conditions of the funding. If it is accepted that the outcomes of the SWANI
project are valid and that either of the two digital signature strategies are acceptable, then this will be
applicable to all EU funded projects across the UK.
It has already been noted that this work will continue to be trialled beyond the project period in 2012
and that, once finalised and accepted, it will be implemented beyond that. Hence the outcomes of the
project will be sustained beyond the project period and will continue to be developed.
All of the project outputs will be available on the project website and the long term project contact will
be Dave Howells who will be contactable at dave.howells@colegsirgar.ac.uk.
7    References
All references are included as footnotes on the pages concerned.


8    Appendices (optional)
Appendix A: Welsh Government response to the use of digital pens with EU audit documents.
The following sequence of emails shows the response from the DfES WBL Manager in the Welsh
Government regarding the use of digital pens:


From: Waller, David (DfES - FED) [mailto:David.Waller@Wales.GSI.Gov.UK]
Sent: 02 December 2011 09:42
To: Tony Toole
Cc: Dave Howells; Lewis, Debra (DfES - FED)
Subject: RE: askWBL/q896 - Audit documentation for WBL in Wales

Hi Tony

I can confirm that as long as there original signed copies of all the relevant paperwork it
compliance with the Programme Specification and the European Guidance, this will be
entirely acceptable.

Best regards

David


David Waller
Rheolwr Prosiect Dysgu Seiliedig ar Waith ESF
ESF WBL Project Manager
Document title: SWANI Final Report v2
Last updated : December 2011
                                              Page 12 of 14
Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011



Tel: 01792 765883
Mobile: (07855) 830764
Further Education Division / Yr Is-Adran Addysg Bellach
Department for Education and Skills - Yr Adran Addysg a Sgiliau
Welsh Government - Llywodraeth Cymru

Welsh Government/Llywodraeth Cymru
Tel: (01792) 765883 (Office)
Tel: (07855) 830764 (Mobile)
Email: david.waller@wales.gsi.gov.uk
Many programmes and projects operated through Welsh Government are part-financed
by the European Union European Social Fund through The West Wales and the Valleys ESF
Convergence Programme & The East Wales Regional Competitiveness and Employment
Programme.


From: Doyle, Jayne (DfES - CSD)
Sent: 29 November 2011 16:11
To: Waller, David (DfES - FED)
Cc: Jarrett, Michael (DfES - CSD)
Subject: FW: askWBL/q896 - Audit documentation for WBL in Wales

Good Afternoon Dave

Before I reply to Tony Toole from Coleg Sir Gar do you think you will be able to help with
this query. As far as we are concerned what they are suggesting seems ok but obviously we
would need clarification regarding EU requirements.

Thanks Dave

Kind regards
Jayne


From: Tony Toole [mailto:tony.toole@e-college.ac]
Sent: 29 November 2011 13:39
To: Doyle, Jayne (DfES - CSD)
Cc: Dave.Howells@colegsirgar.ac.uk
Subject: Audit documentation for WBL in Wales

Dear Jayne,

I have been working for Coleg Sir Gâr during 2011 on a JISC funded project to digitise the
administrative and management forms used in their work based learning programme. The
purpose of the exercise is to make the process more efficient, ensure consistent data entry
for all forms in the system and to increase document security.
Document title: SWANI Final Report v2
Last updated : December 2011
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Project Identifier: SWANI
Version: v2
Contact: Tony Toole
Date: December 2011


We are aware, of course, that the audit trail of documents signed by authorised signatories
is an EU and WAG requirement. In order to meet this requirement, whilst maintaining a fully
digitised recording system, we propose to issue digital pens to all signatories. These pens
will allow handwritten signatures to be entered on to printed copies of the appropriate
forms, but will also add digitised versions of those signatures with the time and date of the
entry to the computerised records of those forms. All of the digitised forms have the same
format and content as the paper based forms.

My expectation is that the provision of a hard copy, hand signed audit trail of documents
will meet the EU/WAG requirements, but It is clearly necessary to have this confirmed by
those responsible for the WBL programme. As an auditor for the programme, I would be
grateful for your response to this proposed arrangement. I would also be grateful for
contact details for anyone else in the audit team that you think I should consult.

I look forward to hearing from you.

Best regards

Tony

Professor Tony Toole
Coleg Sir Gâr
email: tony.toole@e-college.ac
mob: 07590693780
skype: tonytoole

All other supporting documentation is available on the project website at:
https://sites.google.com/site/jiscswani/




Document title: SWANI Final Report v2
Last updated : December 2011
                                            Page 14 of 14

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Jisc Swani Project Final Report

  • 1. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: 08/12/11 JISC Final Report Project Information Project Identifier SWANI Project Title Secure Work-based learning Administration through Networked Infrastructure Project Hashtag #swani Start Date January 2011 End Date December 2011 Lead Institution Coleg Sir Gâr Project Director Dave Howells Project Manager Prof Tony Toole Contact email dave.howells@colegsirgar.ac.uk Partner Institutions n/a Project Web URL https://sites.google.com/site/jiscswani/ Programme Name Learning and Teaching Innovation Grants (SWaNI FE) 10/10 Programme Manager Robin Englebright Document Information Author(s) Tony Toole Project Role(s) Project Manager Date 20/11/2011 Filename swani_finalreport_v2.docx URL https://sites.google.com/site/jiscswani/swani_finalreport_v2.docx Access This report is for general dissemination Document History Version Date Comments v1 20/11/2011 v2 08/12/2011 Update based on comments from JISC Programme Manager and additional information from the project team and the Welsh Government regarding compliance with EU regulations. Page 1 of 14 Document title: SWANI Final Report v1 Last updated : November 2011
  • 2. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 Table of Contents NB : This table of contents ‘auto-populates’ - to update the table of contents – place cursor in the table of contents, right-click your mouse, click ’update field’, select appropriate option 1 ACKNOWLEDGEMENTS ............................................................................................................................ 3 2 PROJECT SUMMARY ................................................................................................................................. 3 3 MAIN BODY OF REPORT ........................................................................................................................... 3 3.1 PROJECT OUTPUTS AND OUTCOMES ................................................................................................................ 4 3.2 HOW DID YOU GO ABOUT ACHIEVING YOUR OUTPUTS / OUTCOMES?...................................................................... 5 3.3 WHAT DID YOU LEARN? ................................................................................................................................ 9 3.4 IMMEDIATE IMPACT ................................................................................................................................... 10 3.5 FUTURE IMPACT ........................................................................................................................................ 10 4 CONCLUSIONS ........................................................................................................................................ 11 5 RECOMMENDATIONS ............................................................................................................................. 11 6 IMPLICATIONS FOR THE FUTURE ............................................................................................................ 12 7 REFERENCES ........................................................................................................................................... 12 8 APPENDICES (OPTIONAL) ....................................................................................................................... 12 Document title: SWANI Final Report v2 Last updated : December 2011 Page 2 of 14
  • 3. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 1 Acknowledgements The SWANI project was funded through the JISC Learning and Teaching Innovation Grant Programme. The project team would like to thank the Programme Manager, Rob Englebright, and the programme support team for all their help and guidance during the project period. 2 Project Summary The SWANI project (Secure Work-based learning Administration through Networked Infrastructure) had the overall aim of creating an online administrative system for the work-based learning (WBL) programmes at Coleg Sir Gâr that included a document authentication process that would meet the requirements of the EU Directive on Electronic Signatures and was also acceptable to the Wales Assembly Government. A further aim was to deliver a system that was significantly more time-efficient and cost-effective than the previous paper-based system, as well as enhancing the learning experience. The Joomla open source content management application was chosen for the digitisation exercise and a range of WBL system documents were created that met the needs of the management and administration process in printed form and the intended efficiencies in digitised form. A significant efficiency gain was a single entry requirement for all main data fields that then populated all documents using those fields. This had the added benefit of ensuring data consistency across all documents. The SWANI project explored a number of different options regarding digital signatures and the authentication of documents for audit purposes. The initial plan was to examine the use and acceptance of digital signatures in other areas of European Commission activity and, where such signatures were validated for audit purposes, to use those examples in negotiations for acceptance for the purposes of audit within the work based learning programme. It was accepted at the outset, however, that in the limited timescale of the project, this negotiation was unlikely to be completed. An alternative approach was therefore adopted which met both the requirements of the EC and WAG for physical signatures, and the intention of the project to have a fully digitised administrative and management system for work based learning. The approach was to use a digital pen which both physically recorded signatures, whilst at the same time created a digital facsimile of the signature and added it, together with a time record, to the digitised document. The documents types that this requirement applies to are all related to audit and administration, not to the WBL competence evidence. There are up to 20 administration documents in the system but some are only used once (the learner eligibility form when a new learner joins the scheme, for example), whilst others might be used two or three times (eg, progress records). Some of the forms may not be required at all (change of circumstance, learner redundancy etc). The online record system was completed as planned and the digital pen system was tested with all the digitised audit forms and shown to work as planned. Discussions were conducted with appropriate authorities to confirm acceptance of the approach for audit purposes and the project concluded with plans for a full trial in 2012 to be carried out in parallel with the existing paper based system. 3 Main Body of Report The existing work based learning programme at Coleg Sir Gâr is paper based. The records of all the learners’ work are held in files that are routinely transported from the college campuses to the workplaces and are verified by signatures of the training advisors, the employers and the learners. Records are kept of learner progress and include periodic reviews. These processes meet the requirements of the system, both from an academic quality point of view and also for audit purposes. However, a significant number of the data entry fields in the forms are common and repeated entry of this data is both time inefficient and invites transcription error. A digitised system therefore, where common data field entry automatically populates all relevant forms, made complete sense. This was a key objective of the SWANI project. A difficulty with the digitisation of the WBL system, however, was the requirement for handwritten signatures on audit documents. Digital signatures are not currently acceptable for the WBL Document title: SWANI Final Report v2 Last updated : December 2011 Page 3 of 14
  • 4. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 programme, despite the drive for an EU wide policy on digital signature acceptability. A solution therefore had to be found if a fully digitised system was to be created. These considerations defined the aims and objectives of the SWANI project: The broad aim of the SWANI project was to create a fully online work-based learning management, administrative and learner support system that met the audit requirements of the EU and the Welsh Assembly Government. It also aimed to deliver a system that was significantly more time-efficient and cost-effective, as well as enhancing the learning experience. The specific objectives of the SWANI project were to: Create a fully online management, administrative and learner support system for work-based learners; Implement a system of applying digital signatures to documents that satisfied the audit requirements of the EU and the Welsh Assembly Government; Carry out a trial of the online system in parallel with the existing paper-based system to evaluate and quantify the benefits; Provide a detailed report on the SWANI project outcomes that could be used by other institutions in the UK facing similar issues. 3.1 Project Outputs and Outcomes Output / Outcome Type Brief Description and URLs (where applicable) (e.g. report, publication, software, knowledge built) SWANI Project Website The SWANI Project website is a repository of all the project documents and outputs. This includes a record of progress in all of the Workpackages and includes links to all the deliverables. The URL is https://sites.google.com/site/jiscswani/ SWANI Project Blog The SWANI Project blog was a reflective record of the progress of the project and provided links to key outputs. The URL is http://swaniprojectblog.blogspot.com/ SWANI Work Based Learning The WBL website is based on the Joomla open source content Website management system application and was a major SWANI project output. The website URL is http://vcdemo.co.uk/swani/index.php Enterprise Architecture WBL The CSG WBL analysis used Enterprise Architecture modelling Analysis Report to portray the administrative processes. The report can be viewed at: https://sites.google.com/site/jiscswani/SWANIEAReport.doc Digital Signature Enabled Forms A range of forms were digitally enabled as part of the digital pen testing programme. These are available for viewing at https://sites.google.com/site/jiscswani/home/digital- signatures/signature-enabled-forms Digital Signature Testing Report The digital signature system was implemented and tested. It was shown to work as planned and is now being introduced to the WBL Training Advisor team. Details are shown at https://sites.google.com/site/jiscswani/home/digital- signatures/negotiation-documents SWANI Project Report The final deliverable of the project was the project final report which summarises the project activities and deliverables. The report can be downloaded at https://sites.google.com/site/jiscswani/swani_finalreport_v1.docx Document title: SWANI Final Report v2 Last updated : December 2011 Page 4 of 14
  • 5. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 3.2 How did you go about achieving your outputs / outcomes? The SWANI project set out to develop a fully online administrative and learner support system for the work-based learning programme at Coleg Sir Gâr. The existing systems are all paper-based for the reason that the Welsh Assembly Government requires original signatures on all auditable documents, as does the European Union who partly fund the WBL programme in Wales. The WAG specification of Evidence Requirements for Funding and Payment states that ‘Electronic signatures on any form and electronically copied versions are not sufficient for European Union audit purposes and will not be accepted by the Welsh Assembly Government.’ However, the project team was aware of the ongoing debate in the EU about the use of electronic 1 signatures based on the Directive on a Community Framework for Electronic Signatures that was originally issued in 1999. This has been developed and revised since that time with the express intention to: make electronic signatures easier to use and help them become legally recognised within the Member States. The SWANI project planed to explore further the current legal status and technologies involved in this development and use the information in the planning for its own technical implementation. This objective was pursued by the project, but was developed in parallel to another more pragmatic solution involving the use of digital pens as described later in this report. There were two main developments to be carried out by the SWANI project: 1. The Online WBL Management and Administrative System The online WBL management system was based on the open source content management system Joomla. The e-Learning Unit at Coleg Sir Gâr, where the project team was, and includes the Web Programmer who built the platform, has considerable experience in the use of the Joomla application in the delivery of online distance learning. The main task was the creation of digital versions of the current paper documents and presenting them in an intuitive and user- friendly way for the users through a Joomla implementation built for that purpose. 2. The Digital Signature System The project researched digital signature systems that are in use globally, and evaluated applications/products that met the system requirements. This included consideration of the use of third party digital signature authentication services that provided cost-effective solutions. It also explored the use of digital pens as a potential solution and examined a number of different products. The top level system requirements included: A system that met the audit requirements of the EU and WAG for the WBL programme in Wales; A system that was simple and easy to use by the signatories (Training Advisors, Employers, Learners); A system that was easily installed/hosted/managed and requires only administrative maintenance; A system that was cost-effective and delivered quantifiable cost savings compared with the paper based system it replaced. Initial Analysis The project began with an analysis of the existing paper based administrative, management and audit systems involved in the WBL programme delivered by Coleg Sir Gâr. This was carried out using 2 Enterprise Architecture modelling and made use of the JISC-CETIS Archi EA modelling application . This involved interviews with all of the stakeholders involved in the work based learning processes including the learners, the employers, the training advisors, the auditors the programme management and external agencies such as the Careers Service. 1 http://europa.eu/legislation_summaries/information_society/l24118_en.htm 2 http://archi.cetis.ac.uk/ Document title: SWANI Final Report v2 Last updated : December 2011 Page 5 of 14
  • 6. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 An evaluation report was produced that included a number of EA mappings and identified the key actors and business processes involved: Document title: SWANI Final Report v2 Last updated : December 2011 Page 6 of 14
  • 7. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 This allowed the creation of a plan for the digitisation of all the relevant forms and documents and to review the associated processes and procedures. For example, the Training Advisor Initial Assessment Process when a new learner joins the programme: The Digitisation Process The project team created a website using the Joomla application with the associated support software and database. It then constructed digitised versions of all the auditable documents that were used by 3 the work based learning staff to record the progress of learners through the system . A key benefit arising from this process was that all key data fields, such as names, addresses and other related information, that were repeated on many of the forms, only had to be entered once. This having been done, the same data automatically populated the same fields in all the other documents. 3 http://vcdemo.co.uk/swani/index.php Document title: SWANI Final Report v2 Last updated : December 2011 Page 7 of 14
  • 8. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 The screenshot shows how a drop-down list of forms is available on the site for all the users to select, and each of these is available to be completed online according to their accredited status as a stakeholder. The fact that the forms are all available online, means that the details can be entered from whatever location, institutional or work based, that is appropriate. This avoids the risk in the existing paper based system of losing documents that are manually transported between different 4 locations. Further information about the Joomla CMS can be found on the project website . Digital Signature Systems The project initially set out to establish a system of electronic signature usage that would be acceptable to the European Union and to the Welsh Assembly Government. The team identified a number of examples where such signatures are used for audit purposes and also EU policy documents that had the express objective of establishing digital signatures as the preferred method of 5 verifying auditable documentation . However, it was always accepted that agreement on the use of such a system for the WBL programme in Wales, although highly desirable, was not achievable in the timescale of the SWANI project. The project team therefore explored an alternative solution that would satisfy the requirement for a handwritten signature on all auditable documents, whilst at the same time maintaining a fully digitised record system. This was through the use of digital pens. The Digital Pen System There are a number of commercial digital pen systems that record what is written by the pen and then download that information to computers running the associated software. The criteria that the SWANI project applied were that: The pens should be wireless, rechargeable and should act as normal pens as well as recording digitally what is written; The pens should have the capacity to transmit the digitised content remotely to the Joomla server where the forms would be automatically updated; The handwritten signatures and the forms used to record them satisfied the audit requirements of WAG and the EU; The cost of the pens and software should be low enough to achieve the overall cost efficiencies planned for the digitised system. 6 The solution chosen was the Destiny Fastdox product . This met all of the above criteria and the system is shown diagrammatically below: 4 https://sites.google.com/site/jiscswani/JoomlaBriefingDocument.docx?attredirects=0 5 https://sites.google.com/site/jiscswani/home/digital-signatures/negotiation-documents 6 http://www.destinywireless.com/flash/#/home/intro/ Document title: SWANI Final Report v2 Last updated : December 2011 Page 8 of 14
  • 9. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 The product works by installing the software on the target computer as an additional printer in the list available when documents are printed. When any of the WBL forms from the drop down list are selected and the Fastdox printer is selected, the form is printed with a matrix of dots in the background that are used by the pen to record the position of the pen when it writes on the page. These digital images are transmitted by Bluetooth via a mobile phone to the host computer where the form was originally printed. The PDF version of the form held on that computer is automatically populated with the facsimile of the written content in exactly the same position on the page as the handwritten version. The digitised version is also time-stamped and any subsequent writing on the same physical version results in a new updated digital version with its own time stamp. The original paper version is filed as before for audit purposes, but the digitised version means that WBL management and administrative staff can gain online access to the information at any time without having to be in the same place as the file. The two versions are shown in the example below: Physical version Digital version It can be seen that the digitised version is a faithful reproduction of the original. The system has been trialled by the WBL team and has been evaluated by the Welsh Office WBL auditors. The digitised system and the use of the digital pen have been approved in principle (see Appendix A) and will move forward to a full trial in 2012. 3.3 What did you learn? Evaluation activities In the evaluation phase of the project the JISC-CETIS Archi Enterprise Architecture tool was used to model the administrative and management processes. The advantage of using EA modelling techniques is that it explicitly links the business process layer to the application and technical layers. This means that, for a technology supported business process improvement project such as SWANI, a mapping of the business processes to the support infrastructure is easily achieved and portrayed schematically. Document title: SWANI Final Report v2 Last updated : December 2011 Page 9 of 14
  • 10. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 The functionality of the Archi tool is excellent, and is particularly supportive of users who are new to the methodology. The ‘Magic Connector’ relationship option, for example, automatically offers the options available for relationships between the objects that make up the model being constructed. The key benefit from using EA modelling was the way it facilitated stakeholder conversations about how administrative and management processes happened and how changes might improve effectiveness and efficiency. Research activities The research into digital signatures revealed that there were clear precedents for the use of such signatures in EU audit processes. It is therefore concluded that this is a valid avenue to pursue for the future of WBL in Wales. The planned parallel trial of the digital system in 2012 will provide a vehicle for taking those negotiations forward. The pragmatic solution chosen to meet the objectives of the SWANI project, that of using digital pens, was successful and provided some useful lessons. The first was that simple solutions sometimes make more practical sense than pursuing logically compelling but difficult solutions that rely on high level negotiation. The second lesson was that the digital pen solution was scalable. It could be implemented at a local level to satisfy the needs of a particular programme, or it could be implemented at enterprise level and integrated with institutional MIS systems if that was appropriate. This is potentially important at Coleg Sir Gâr, for example, as the college operates as a partner in a WBL consortium in South West Wales and the expectation is that the system would be rolled out on a much wider scale if the trials are successful and accepted by the other partners. User testing The WBL team at Coleg Sir Gâr have been involved in the SWANI project throughout, and this has included evaluating the digitised version of the paperwork and testing the digital pen system. However, time did not allow a full trial of the system and this was always planned for the end of the project and in 2012. The outcomes of that process will be published outside of the reporting for SWANI. 3.4 Immediate Impact The immediate impact of the SWANI project will be on the way in which the WBL programme at Coleg Sir Gâr is managed and the documentation completed. There is still work to be done in completing digitisation of all the forms, but the major records are available for trials. All of the work to date has been carried out by the project team and the WBL staff at Coleg Sir Gâr. The plan is to involve all other partners in the trials in 2012 and the expectation is that they will participate in the evaluation with a view to implementation on successful completion. All of the feedback during the project has confirmed that the efficiencies offered by the digitised administrative system are welcomed by all stakeholders. The EA modelling process had the added effect of promoting a re-examination of the WBL management processes themselves, particularly the way they are currently distributed through the Coleg Sir Gâr Faculty structure, with the possibility that organisational benefits may result in addition to the efficiency benefits. 3.5 Future Impact The potential future impact of the SWANI project has already been referred to and could be important at a number of levels. The impact on the institution and the efficiency of its processes is the most obvious. However, there is a reasonable expectation that it will impact at regional level as the trials go ahead. Discussions at a national level will also proceed regarding digital signatures for audit purposes and this may have significant impact on future policy and procedures. The initial feedback from the Welsh Government confirms the validity of the approach used and that it meets EU audit requirements. Document title: SWANI Final Report v2 Last updated : December 2011 Page 10 of 14
  • 11. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 It is hoped that the outcomes of the SWANI project will be of use and benefit to other institutions who are engaged in similar work based learning programmes. The digitisation of administrative procedures and documentation is an obvious route to take and the solution to the audit trail requirements may be of value to others in the education community faced with similar requirements. 4 Conclusions General conclusions The general conclusions that the team has drawn from the SWANI project are that: Full digitisation of the administrative and management documentation for the work based learning programme at Coleg Sir Gâr offers significant efficiencies, operational benefits and data security; The digitisation can be accomplished using open source solutions, such as Joomla, thus adding to the cost efficiencies of the approach; The difficulties of meeting EU and WAG requirements for signatures on all audit documents can be solved in more than one way; The digital pen solution satisfies both the handwritten signature requirement and the plan for a fully digitised system; The outcomes of the SWANI project will allow Coleg Sir Gâr to achieve its objective of implementing a digital administrative and management document system for WBL during 2012. Conclusions relevant to the wider community The implementation of a digitised audit process that satisfies the requirements of EU programmes will be of value to other institutions delivering similar programmes; The implementation of an open source document management system may also be of use to other institutions looking for similar cost effective solutions; The use of Enterprise Architecture modelling is a very effective instrument in business planning and the JISC-CETIS Archi tool is an excellent and freely available application for this purpose. Conclusions relevant to JISC The immediate conclusion that the project team came to was that the JISC LTIG programme was a very effective way of allowing institutions to solve specific TEL issues; A related conclusion was that the issues being addressed were very likely to be faced by others in the JISC community and that the solutions found would be transferable; It was felt important that the success of the Archi tool should be highlighted. 5 Recommendations General recommendations It is recommended that: The institution and the regional WBL programme partnership complete the parallel trial planned for 2012; The digital pen system be approved for general use in audit purposes and that negotiations continue regarding the approval of digital signatures generally for this purpose; The trials in 2012 be used to further refine the digital system for WBL administration and that this be approved as the preferred regional approach. Recommendations for the wider community That open source solutions for institutional document management and storage should be a serious consideration; That Enterprise Architecture modelling is an effective tool in management planning and that the JISC-CETIS Archi application is recommended; Document title: SWANI Final Report v2 Last updated : December 2011 Page 11 of 14
  • 12. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 That digital pen technology can be recommended as an effective way of authenticating audit documents. Recommendations for JISC That the LTIG programme and other small scale innovation grant initiatives be continued (despite difficult financial conditions) as a highly cost effective way of promoting TEL; That open source, web 2.0 and cloud computing solutions should be promoted to the education community as a cost-effective way of using technology in support of learning. 6 Implications for the future The implications for the future relate to anyone involved in European funded projects that are constrained by the audit conditions of the funding. If it is accepted that the outcomes of the SWANI project are valid and that either of the two digital signature strategies are acceptable, then this will be applicable to all EU funded projects across the UK. It has already been noted that this work will continue to be trialled beyond the project period in 2012 and that, once finalised and accepted, it will be implemented beyond that. Hence the outcomes of the project will be sustained beyond the project period and will continue to be developed. All of the project outputs will be available on the project website and the long term project contact will be Dave Howells who will be contactable at dave.howells@colegsirgar.ac.uk. 7 References All references are included as footnotes on the pages concerned. 8 Appendices (optional) Appendix A: Welsh Government response to the use of digital pens with EU audit documents. The following sequence of emails shows the response from the DfES WBL Manager in the Welsh Government regarding the use of digital pens: From: Waller, David (DfES - FED) [mailto:David.Waller@Wales.GSI.Gov.UK] Sent: 02 December 2011 09:42 To: Tony Toole Cc: Dave Howells; Lewis, Debra (DfES - FED) Subject: RE: askWBL/q896 - Audit documentation for WBL in Wales Hi Tony I can confirm that as long as there original signed copies of all the relevant paperwork it compliance with the Programme Specification and the European Guidance, this will be entirely acceptable. Best regards David David Waller Rheolwr Prosiect Dysgu Seiliedig ar Waith ESF ESF WBL Project Manager Document title: SWANI Final Report v2 Last updated : December 2011 Page 12 of 14
  • 13. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 Tel: 01792 765883 Mobile: (07855) 830764 Further Education Division / Yr Is-Adran Addysg Bellach Department for Education and Skills - Yr Adran Addysg a Sgiliau Welsh Government - Llywodraeth Cymru Welsh Government/Llywodraeth Cymru Tel: (01792) 765883 (Office) Tel: (07855) 830764 (Mobile) Email: david.waller@wales.gsi.gov.uk Many programmes and projects operated through Welsh Government are part-financed by the European Union European Social Fund through The West Wales and the Valleys ESF Convergence Programme & The East Wales Regional Competitiveness and Employment Programme. From: Doyle, Jayne (DfES - CSD) Sent: 29 November 2011 16:11 To: Waller, David (DfES - FED) Cc: Jarrett, Michael (DfES - CSD) Subject: FW: askWBL/q896 - Audit documentation for WBL in Wales Good Afternoon Dave Before I reply to Tony Toole from Coleg Sir Gar do you think you will be able to help with this query. As far as we are concerned what they are suggesting seems ok but obviously we would need clarification regarding EU requirements. Thanks Dave Kind regards Jayne From: Tony Toole [mailto:tony.toole@e-college.ac] Sent: 29 November 2011 13:39 To: Doyle, Jayne (DfES - CSD) Cc: Dave.Howells@colegsirgar.ac.uk Subject: Audit documentation for WBL in Wales Dear Jayne, I have been working for Coleg Sir Gâr during 2011 on a JISC funded project to digitise the administrative and management forms used in their work based learning programme. The purpose of the exercise is to make the process more efficient, ensure consistent data entry for all forms in the system and to increase document security. Document title: SWANI Final Report v2 Last updated : December 2011 Page 13 of 14
  • 14. Project Identifier: SWANI Version: v2 Contact: Tony Toole Date: December 2011 We are aware, of course, that the audit trail of documents signed by authorised signatories is an EU and WAG requirement. In order to meet this requirement, whilst maintaining a fully digitised recording system, we propose to issue digital pens to all signatories. These pens will allow handwritten signatures to be entered on to printed copies of the appropriate forms, but will also add digitised versions of those signatures with the time and date of the entry to the computerised records of those forms. All of the digitised forms have the same format and content as the paper based forms. My expectation is that the provision of a hard copy, hand signed audit trail of documents will meet the EU/WAG requirements, but It is clearly necessary to have this confirmed by those responsible for the WBL programme. As an auditor for the programme, I would be grateful for your response to this proposed arrangement. I would also be grateful for contact details for anyone else in the audit team that you think I should consult. I look forward to hearing from you. Best regards Tony Professor Tony Toole Coleg Sir Gâr email: tony.toole@e-college.ac mob: 07590693780 skype: tonytoole All other supporting documentation is available on the project website at: https://sites.google.com/site/jiscswani/ Document title: SWANI Final Report v2 Last updated : December 2011 Page 14 of 14