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HomeMy WebLinkAbout2025-03-04; City Council; 05; Revise City Council Policy No. 80 – Electronic SignaturesCA Review GH Meeting Date: March 4, 2025 To: Mayor and City Council From: Geoff Patnoe, City Manager Staff Contact: Gina Herrera, Assistant City Attorney gina.herrera@carlsbadca.gov, 442-339-5123 Subject: Revise City Council Policy No. 80 – Electronic Signatures Districts: All Recommended Action Adopt a resolution approving revisions to City Council Policy 80 – Electronic Signatures. Executive Summary Staff are proposing changes to City Council Policy No. 80 to simplify the policy while continuing to allow for and encourage the use of electronic signatures where it is feasible and legally permissible to do so. Expanding the use of electronic signatures in city processes improves workflow efficiencies and reduces the need to print, file and store paper documents, in keeping with the City Council’s goals of protecting the environment and natural resources and being a model for effective and efficient local government. Under City Council Policy No. 1, City Council policies may be adopted, amended, or rescinded only by a resolution receiving four affirmative votes from the City Council. Explanation & Analysis City Council Policy No. 80 and Administrative Order No. 75, which were both first adopted in 2014, address the use of electronic signatures on city documents and agreements. Since their adoption, the use of electronic signatures has become more prevalent and the technology for processing electronic signatures has improved. Staff have reviewed the City Council policy and the administrative order and are proposing changes to both documents. The simplified City Council policy will remain relevant even if the use of electronic signatures expands or new technologies emerge; any changes needed to address the new uses or technologies can be made to the administrative order. The administrative order is also being revised to provide more detailed guidance for city staff on the use of electronic signatures. The order includes a table for staff identifying various types of city documents and the allowable signatures for each. The administrative order is provided as Exhibit 3, the previous order is provided as Exhibit 4 and a table explaining the proposed changes between the new and previous orders is provided as Exhibit 5. March 4, 2025 Item #5 Page 1 of 17 City staff have been using digital signature technology such as DocuSign for signing contracts since 2014 and that use has greatly expanded over time. The administrative order continues the use of digital signatures on contracts and agreements but will also allow for other types of electronic signatures to be used on other city documents, such as routine correspondence, internal memos and purchase orders. The administrative order also allows for the use of electronic signatures on resolutions and ordinances. Fiscal Analysis Revising City Council Policy No. 80 will have no fiscal impact on the city. Next Steps If the City Council adopts the proposed resolution revising City Council Policy No. 80, the City Manager will then issue the revised Administrative Order No. 75, attached as Exhibit 3. Environmental Evaluation This action does not require environmental review because it does not constitute a project within the meaning of the California Environmental Quality Act under California Public Resources Code Section 21065 in that it has no potential to cause either a direct physical change or a reasonably foreseeable indirect physical change in the environment. Exhibits 1. City Council resolution 2. City Council Policy No. 80 with revisions shown 3. Proposed Administrative Order No. 75 4. Existing Administrative Order No. 75 5. Table highlighting differences between existing and proposed Administrative Order No. 75 March 4, 2025 Item #5 Page 2 of 17 uocus1gn t::nvelope IU: (.;ti1Al,;/UJ-J!:ll::ti-4t-t-1-!:IUU4-oUl:lU;:!AUUtitit-U RESOLUTION NO. 2025-060 A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CARLSBAD, CALIFORNIA, APPROVING REVISIONS TO CITY COUNCIL POLICY NO. 80 - ELECTRONIC SIGNATURES WHEREAS, the use of electronic signatures increases workflow efficiencies and reduces the use of paper; and WHEREAS, the City Council adopted City Council Policy No. 80 -Electronic Signatures in 2014 to address the use of electronic signatures on city documents and agreements; and WHEREAS, since the adoption of City Council Policy No. 80, the use of electronic signatures has become more prevalent and the technology for processing electronic signatures has improved; and WHEREAS, the revised City Council Policy No. 80 provides a policy statement encouraging the use of electronic signatures as operationally feasible, where technology permits and as otherwise appropriate; and WHEREAS, specific rules and requirements regarding the use of electronic signatures on internal and external city documents will be adopted by an administrative order issued by the City Manager. NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Carlsbad, California, as follows: 1. That the above recitations are true and correct. 2. That revised City Council Policy No. 80 (Attachment A) is adopted. PASSED, APPROVED AND ADOPTED at a Regular Meeting of the City Council of the City of Carlsbad on the 4th day of March 2025, by the following vote, to wit: AYES: NAYS: ABSTAIN: ABSENT: Blackburn, Bhat-Patel, Acosta, Burkholder, Shin. None. None. None. KEITH BLACKBURN, Mayor SHERRY FREISINGER, City Clerk (SEAL) City Council POLICY STATEMENT Subject: Electronic Signatures Purpose Policy No. Date Issued Attachment A 80 03/04/2025 Resolution No. 2025-060 This policy authorizes the use of electronic signatures on city documents. This policy does not supersede laws that specifically require a written signature. Background The use of electronic signatures is increasingly prevalent in the public and private sector because it can reduce the paper, time and cost associated with transmitting, approving and storing physical documents. Using electronic signatures to increase workflow efficiencies and reduce the use of paper furthers the City Council's goals of protecting the environment and natural resources and being a model for effective and efficient local government. Statement of policy The City Council encourages the use of electronic signatures on internal and external documents when it is operationally feasible, where existing technology permits and as otherwise appropriate. The City Manager in consultation with the City Attorney shall develop and maintain policies and procedures for the use of electronic signatures on city documents. Procedure Refer to Administrative Order No. 75 -Electronic Signatures. Exhibit 2 Policy No. 80 Date Issued 3-11-2014 Resolution No. 2014-036 Subject: Electronic Signatures Purpose This policy authorizes the use of electronic signatures on city documents. To enable the City of Carlsbad to accept an approved electronic signature, in lieu of a written signature, on a document in which a signature is required or used, which complies with the requirements of Government Code section 16.5. This policy does not supersede laws that specifically require a written signature. This policy does not limit the right or option to conduct the transaction on paper or in non-electronic form and the right to have documents provided or made available on paper. Background The use of electronic signatures on legally binding documents has become is increasingly prevalent in the public and private sector but has yet to find widespread adoption by public entities. The benefits of electronic signatures are simple and numerous: they cut down on because it can reduce the paper, time and cost associated with transmitting, and approving and storing physical documents., and they can offer an easily accessible audit trail of the modification, editing, and approval/ signature of documents. Using electronic signatures to increase workflow efficiencies and reduce the use of paper furthers the City Council’s goals of protecting the environment and natural resources and being a model for effective and efficient local government. This policy will authorize the use of electronic signatures on the City of Carlsbad documents while allowing the city to strike a balance between flexibility and the need for signature security and integrity. Statement of policy Calibri 12 point font, 85% black here. The City Council hereby authorizes encourages the use of electronic signatures on internal and external documents when it is operationally feasible, where existing technology permits and as otherwise appropriate. The City Manager in consultation with the City Attorney shall develop and maintain policies and procedures for the use of electronic signatures on city documents. as detailed in Administrative Order No. 75 – Electronic Signatures, which may be amended from time to time. March 4, 2025 Item #5 Page 5 of 17 City Council POLICY STATEMENT Electronic Signatures Date Page 2 To the fullest extent permitted by law, the City of Carlsbad accepts e-signatures as legally binding and equivalent to handwritten signatures to signify an agreement in accordance with California Government Code section 16.5. This policy applies to all employees of the City of Carlsbad, and governs all uses of electronic signatures and electronic records used to conduct the official business of the City of Carlsbad. Such business may include, but not be limited to electronic communications, transactions, contracts, permits and other official purposes, both internal and external to the city. Where a city policy requires that a record have the signature of an authorized person that requirement is met when the electronic record has associated with it an electronic signature using a city approved electronic signature method. Where a city policy requires a written document, that requirement is met when an electronic record has associated with it an electronic signature using a city approved electronic signature method. The City of Carlsbad's right or option to conduct a transaction on paper or in non-electronic form shall not affect the City of Carlsbad's right, option or obligation to have documents provided or made available in paper format. Approved and automated processes for a City of Carlsbad transaction are automatically subject to the provisions of this policy. Periodic reviews will be implemented for appropriateness and continued applicability of electronic signatures. If the parties have agreed to conduct a transaction by electronic means, the parties are required to utilize the city's electronic signature system for approved, electronically signed documents and that all applicable security processes for authentication be followed. Where a legal requirement, beyond city policy, requires a written document, that requirement is met when an electronic record has associated with it an electronic signature using an approved electronic signature method, which complies with California state law. Appropriate procedures must be used to confirm that the person signing the record has the appropriate authority. This policy applies only to transactions between parties, which have agreed to conduct transactions by electronic means with the use of the city's approved electronic signature method. If parties have agreed to conduct a transaction by electronic means and a law requires a person to provide, send, or deliver information in writing to another person, the requirement is satisfied if the information is provided, sent or delivered, in an electronic record capable of retention by the recipient at the time of receipt. An electronic record is not capable of retention by the recipient if the sender or its information processing system inhibits the ability of the recipient to print or store the electronic record. This policy shall not apply to any transaction that requires a person's signature to be signed in the presence of a notary public. The final approval of any electronic signature method will be by the City Manager and City Attorney, with the recommendation of the Information Technology Director. In determining whether to approve an electronic signature method, consideration will be given to the systems March 4, 2025 Item #5 Page 6 of 17 Electronic Signatures Date Page 3 and procedures associated with using that electronic signature, and whether the use of the electronic signature is at least as reliable as the existing method being used. In the event that it is determined that an approved electronic signature method is no longer trustworthy, the City Manager must revoke the approval of that electronic signature method. If there is continued significance for the electronic signatures, which used the revoked method, the City Manager will take steps to see that any valid records signed with the revoked electronic signature method are signed again either with a written signature or with an approved electronic signature method. Procedure Refer to Administrative Order No. 75 – Electronic Signatures. March 4, 2025 Item #5 Page 7 of 17 Exhibit 3 City Hall 1200 Carlsbad Village Drive  Carlsbad, CA 92008  442-339-2820  www.carlsbadca.gov Administrative Order No. 75 This order supersedes Administrative Order No. 75 dated April 14, 2014 Date: CURRENT DATE To: All City Departments From: Geoff Patnoe, City Manager Subject: Electronic Signature Policy and Procedure REFERENCE: City Council Policy 80 – Electronic Signatures. PURPOSE: The use of electronic signatures is intended to make city business practices more efficient by allowing more automated workflows and eliminating the need to print, file and store paper documents. This policy establishes when electronic signature technology may replace a hand- written signature, with the goal of encouraging the use of paperless, electronic documents whenever appropriate and allowed by law. This policy allows the city to accept an approved electronic signature, in lieu of a written signature, on a document in which a signature is required or used, which also complies with the requirements of the California Government Code Section 16.5, is accessible and conforms to Revised Section 508 Standards and Web Content Accessibility Guidelines 2.0 Level AA Success Criteria (ADA compliance requirements for electronic content) and this policy. While the use of electronic signatures is suggested and encouraged, this policy does not require any city department to use electronic signatures, nor can the city mandate that any third party signing a document use electronic signatures. This policy applies to documents requiring a signature of any person where the signature is intended to show authorship, approval, authorization, or certification, as allowed by law. It is the policy of the city to encourage the use of electronic signatures in all internal and external activities, documents, and transactions where it is operationally feasible to do so, and where existing technology permits. In such situations, affixing an electronic signature to the document in a manner consistent with this policy shall satisfy the city's requirements for signing a document. As used in this policy, the term "signature" includes using initials on a document instead of a signature. March 4, 2025 Item #5 Page 8 of 17 {city of Carlsbad Admininstrative Order No. 75 – Electronic Signature Policy and Procedure 2 BACKGROUND: The use of electronic signatures on legally binding documents has become increasingly prevalent. The benefits of electronic signatures are simple and numerous: they cut down on the paper, time and cost associated with transmitting and approving physical documents and can offer an easily accessible audit trail of the modification, editing, and approval of documents. The legality and use of electronic signatures are governed by federal and state law. (See 15 U.S.C. §§ 7001, et seq. [U.S. Federal Electronic Signatures in Global and National Commerce Act]; California Government Code Section 16.5; California Civil Code Section 1633.1, et seq.) In 1995, the California Legislature enacted AB 1577 which, among other things, added Government Code Section 16.5, to authorize public entities to accept digital signatures if the signatures comply with stringent verification requirements. In 1999, California adopted a version of the Uniform Electronic Transactions Act (UETA)(California Civil Code Sections 1633.1 to 1633.17), providing that electronic signatures would have the same legal effect as a wet or manual signature. In 2000, the federal government enacted the Electronic Signatures in Global and National Commerce Act (ESIGN) which mandated the same treatment of electronic signatures in interstate or foreign commerce (15 USC Section 7001 et seq.) In 2016, AB 2296 clarified that a digital signature may be used to satisfy the requirements of an electronic signature under UETA. The bill also revised Government Code Section 16.5 by specifying that if a public entity elects to use a digital signature that meets specific requirements, the digital signature has the same force and effect of a manual signature in any communication with the public entity. POLICY: Definitions: "Digital Signature" is an electronic identifier, created by computer, intended by the party using it to have the same force and effect as the use of a manual signature if and only if it embodies the following attributes pursuant to Government Code Section 16.5: • It is unique to the person using it; • It is capable of verification; • It is under the sole control of the person using it; • It is linked to data in such a manner that if the data are changed, the digital signature is invalidated; and • It conforms to regulations adopted by the California Secretary of State. "Electronic" relates to technology having electrical, digital, magnetic, wireless, optical, electromagnetic, or similar capabilities. "Electronic Record" is a record created, generated, sent, communicated, received, or stored by electronic means. March 4, 2025 Item #5 Page 9 of 17 Admininstrative Order No. 75 – Electronic Signature Policy and Procedure 3 "Electronic signature or e-signature" means an electric sound, symbol, or process attached to or logically associated with an electronic record and executed or adopted by a person with the intent to sign the electronic record. Electronic signature is a broad generic term for a variety of electronic methods of approving or signing documents without the use of paper and ink. As defined above, a digital signature is a type of electronic signature. "Record" is information that is inscribed on a tangible medium or that is stored in an electronic or other medium and is retrievable in perceivable form. Documents or forms are records. Choosing Electronic Signatures vs. Digital Signatures As defined above, electronic signatures include a wide range of methods of approving or signing documents without the use of paper and ink. Some methods of creating electronic signatures include typing a name at the end of an email, scanning a signature image and inserting the image in a document, or checking an approval box on a form. In contrast, digital signatures include a form of encryption which protects the authenticity of the document and prevents the document from being altered after it has been signed. Digital signatures can only be generated by the use of specialized software. While digital signatures are required on certain documents, standard e-signatures are sufficient and recommended for most internal signing. • Electronic Signature: o Routine memos, correspondence and documents intended for use within the city or with outside agencies o Legislative documents (ordinances, resolutions, etc.) o Personnel forms and memos (pre-employment, active employees, retirees, etc.) o Travel Logs o Credit Card Statements • Digital Signature: o Contracts and agreements o Sensitive legal, contractual or personnel documents o Assorted legal or financial documents o Final real estate transactions (restrictions apply to recorded documents, including those documents that convey interests in real property) Attachment A to this Administrative Order includes a matrix identifying common city documents and the types of signatures appropriate for each. General Provisions • In any document generated, used or accepted by the city in which a signature is required, the use of an electronic signature will have the same force and effect as a March 4, 2025 Item #5 Page 10 of 17 Admininstrative Order No. 75 – Electronic Signature Policy and Procedure 4 handwritten signature, so long as the electronic signature complies with the requirements of this Administrative Order. •To the fullest extent permitted by law, the city accepts electronic signatures as legally binding and equivalent to handwritten signatures. •This policy applies only to transactions between parties that have agreed to conduct transactions by electronic means with the use of the city's approved electronic signature method. When a document is electronically signed by all parties, the city will provide a copy of the electronically signed document to the other parties in an electronic format that is capable of being retained and printed. •The final approval of any electronic signature method will be by the City Clerk Services Director and the City Attorney shall determine acceptable technologies and vendors consistent with industry best practices to ensure the security and integrity of the data and the signature. The City Clerk Services Director shall further determine the documents for which the city will accept electronic signatures. Periodic reviews will be implemented for appropriateness and continued applicability of electronic signatures. •This Administrative Policy shall not apply to any transaction that requires a person's signature to be signed in the presence of a notary public. Records Retention It is the responsibility of the initiating department to retain, and store, signed documents in accordance with the requirements detailed in the city’s records retention schedule, unless the City Clerk’s Office is the office of record. Violations •Employees who falsify electronic signatures or otherwise violate this policy are subject to disciplinary action and criminal prosecution under applicable city and state laws. •It is a violation of this administrative order for an individual to sign on behalf of another individual unless he or she has documented proof of specific authority by that individual to affix their electronic signature to a particular electronic record. •Individuals must report any suspect or fraudulent activities related to electronic signatures immediately to any manager or supervisor. ACTION: This Administrative Order is effective immediately. _________________________________ _________________________________ Geoff Patnoe, City Manager Date Attachments: A.Common Types of Documents March 4, 2025 Item #5 Page 11 of 17 Admininstrative Order No. 75 – Electronic Signature Policy and Procedure 5 Attachment A – Common Types of Documents Examples of common types of documents are listed below. Signing authority is permitted only to the extent each signer has requisite signature authority. Document Type Type of Signature Required Notes Memos, Forms, Letters, and Other Correspondence Electronic signature Electronic Signature is recommended/Must maintain proper signing authority Internal purchase/accounting documentation, Internal HR Forms, Payroll Direct Deposit Forms Electronic signature Electronic Signature is recommended/Must maintain proper signing authority City issued checks Wet/Manual signature required A facsimile signature may be used in lieu of a manual signature (Gov. Code § 5501) City issued wires, EFT, ACH Digital signature Transactions subject to verification by financial institutions Contract/Agreement (when any party uses a notarized signature) Wet/Manual signature required If one party is required to sign and notarize the agreement, then all signatures must be wet/manual Contracts/ Agreements Digital signature Digital Signature may be used by all parties, if no party must sign and notarize Resolutions/Ordinances/ Minutes Electronic signature Electronic Signature is recommended/Must maintain proper signing authority Certificates, Permits Electronic signatures to the extent permitted by law Should work with City Attorney’s Office to determine where applicable laws permit electronic signatures Documents Requiring Notarization Wet/Manual signature required All parties that require notarized signatures must sign using a “wet” signature Documents Requiring Recordation Wet/Manual signature required All parties that require notarized signatures for documents that are being recorded must sign using a “wet” signature March 4, 2025 Item #5 Page 12 of 17 Admininstrative Order No. 75 – Electronic Signature Policy and Procedure 6 Document Type Type of Signature Required Notes Contractual Bonds City Attorney’s Office may approve as to form with a digital signature in counterpart, but the parties being bound must use a wet/manual signature The parties being bound (e.g., contractor and surety) must sign all bonds with a wet/manual signature, because they require notarization Bond Issuance Wet/Manual signature required Final determination of acceptable signature method subject to determination by bond counsel March 4, 2025 Item #5 Page 13 of 17 Exhibit 4 March 4, 2025 Item #5 Page 14 of 17 (1~ CITY OF • CARLSBAD Administrative Order No. 75 Date: April 14, 2014 To: All City Departments From: Steve Sarkozy, City Manager Electronic Signature Subject: PURPOSE: In order to enable the City of Carlsbad with the ability to automate multiple processes this proposal recommends implementing an electronic approval and signature procedure. PROCEDURE The electronic signature process will be managed by the City Attorney, City Manager, Assistant City Clerk, and Chief Technology Officer (collectively "Executive Team"). The Executive Team will oversee the implementation of the security and technology governing the automation process in order to assure the adherence to State law, California Government Code Section 16.5. Implementation and Security Procedures l. Using methodologies identified by the Executive Team, electronic signatures will be implemented depending on the risks associated with the transaction, and all relevant State and City of Carlsbad regulations. The quality and security of the electronic signature method shall be commensurate with the risk and needed assurance of the authenticity of the signer. The Executive Team will sign off for each approved use. 2. Specifications for recording, documenting, and/or auditing the electronic signatures as required for non-repudiation the City Attorney shall determine legal requirements. 3. The Executive Team will 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 order 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 ore-records; and based on such analysis, to designate the transactions in which e-signatures, e-transactions and e-records shall be accepted in place of handwritten or paper documents. 4. The security requirements include but are not limited to, password policies, secure transmission policies, access control policies and other relevant regulations as well as pertinent state regulations. Page 1 of 3 March 4, 2025 Item #5 Page 15 of 17 Administrative Order No. 75 Approval of Electronic Signature Methods 5. The final approval of any electronic signature method will be by the Executive Team. In determining whether to approve an electronic signature method, consideration is given to the systems and procedures associated with using that electronic signature, and whether the use of the electronic signature is at least as reliable as the existing method being used. This determination is made after a technical review of the electronic signature method by the Information Technology department, and the Executive Team. 6. Approved electronic signature methods require use of encryption technology that use public or private key infrastructure and/or certificates, the Information Technology department will be responsible for the administration of such public or private keys and certificates. 7. The approval of an electronic signature method can limit the use of that method to particular electronic records, particular classes of electronic records, or particular city organizations. An electronic signature used outside of its defined parameters will not be considered valid by the city. 8. When an approved electronic signature method is no longer trustworthy, the Executive Team must revoke the approval of that electronic signature method. If there is continued significance for the electronic signatures, which used the revoked method, the Executive Team will take steps to see that any valid records signed with the revoked electronic signature method are signed again with an approved electronic signature method. 9. For a digital signature to be valid, it must be created by a technology accepted for use by the State of California and conform to technologies capable of creating digital signatures as set forth in California Government Code Section 16.5, as amended from time to time: (1) It is unique to the person using it; (2) It is capable of verification; (3) It is under the sole control of the person using it; (4) It is linked to data in such a manner that if the data are changed, the digital signature is invalidated; (5) It conforms to Title 2, Division 7, Chapter 10, of the California Code of Regulations. Rules and Procedures The Executive Team may make rules that: 10. Identify specific transactions that the city is willing to conduct electronically; 11. Identify specific transactions that the city will never conduct electronically; 12. Specify the manner and format in which electronic records must be created, generated, sent, communicated, received and stored, and the systems established for those purposes; 13. If a law requires that an electronic record must be signed electronically, and a third party is used, the third party used must be California state certified; Page 2 of3 March 4, 2025 Item #5 Page 16 of 17 Administrative Order No. 75 14. Specify control processes and procedures as appropriate to ensure preservation, disposition, integrity, security, confidentiality and auditability of electronic records; 15. Identify any other required attributes for electronic records which are specified for corresponding non-electronic records or which are reasonably necessary under the circumstances; 16. Create and maintain a Records Management Program and User Guide. Violations and Sanctions 17. Employees who falsify electronic signatures or otherwise violate this policy are subject to disciplinary action and criminal prosecution under the applicable city and state laws. 18. It is a violation of this administrative order for an individual to sign on behalf of another individual unless he or she has documented proofof specific authority by that individual to affix their electronic signature to a particular electronic record. 19. Individuals must report any suspect or fraudulent activities related to electronic signatures immediately to any manager or supervisor. This order shall be effective July 1, 2014 DATE: APPROVED AS TO FORM: Page 3 of 3 Exhibit 5 EXPLANATION OF PROPOSED CHANGES TO ADMINISTRATIVE ORDER NO. 75 2014 VERSION OF ADMINISTRATIVE ORDER 2025 VERSION OF ADMINISTRATIVE ORDER PURPOSE Contained a brief statement regarding the purpose of the order. The purpose section was expanded to emphasize the benefits of using electronic signatures on a wide variety of city documents. BACKGROUND Not included in the original order. This section was added to provide the governing authority for the use of electronic signatures by including references to relevant laws. POLICY • The administrative order did not differentiate between electronic signatures and digital signatures and did not explain the difference between the two. • The order did not identify the types of documents that could be signed by electronic or digital signature. • Contains definitions and an explanation of the differences between electronic signatures and digital signatures to provide clarity and direction to city staff regarding the appropriate use of each. • A matrix was added as an attachment to the policy identifying common city documents and the types of signatures required. Created an executive team to oversee the implementation and security technology governing the use of electronic signatures and delegated authority to the executive teams for decisions related to the use of electronic signatures. • Authority for the approval of electronic signature methods is delegated to the City Clerk Services Director. • Authority for the approval of acceptable vendors and technology is delegated to the City Attorney. • The City Clerk Services Director will determine the documents for which the city will accept an electronic signature. VIOLATIONS • Provides that violations of the policy, falsifying electronic signatures or signing on behalf of someone else without documented proof of authority to do so could result in disciplinary action or criminal prosecution. • Requires individuals to report any suspect or fraudulent activity related to electronic signatures to a manager or supervisor. No changes were made to this section. March 4, 2025 Item #5 Page 17 of 17