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Document Imaging Policy

Classification number ADM 1303
Framework category Administrative
Approving authority Senior Leadership Team
Policy owner University Secretary
Approval date June 22, 2015
Review date June 2018


The purpose of this Policy is to authorize the establishment of Document Imaging Programs at the University. This Policy also provides standards for the operations of these Programs to allow for the replacement of Source Documents with Images for storage and retention. These standards will ensure the accuracy; reliability and trustworthiness of Images of resulting images can be proven.


For the purposes of this Policy the following definitions apply: 

“Capture” means the creation of an Image from a Document.

“Document” means an original paper or film Record.

“Document Imaging Program” means an authorized program following strict control guidelines and established procedures to ensure the accuracy, reliability and trustworthiness of resulting Images.

“Image” means an electronic reproduction of a Document.

“Indexing” means adding contextual information to an Image to enable the retrieval of the Image and document its origin.

“Official Copy” means the copy of a University Record designated in Local Procedures to satisfy the University’s retention requirements where multiple copies of a Record exist.

“Quality Assurance” means a process which takes place after Indexing to verify the accuracy and completeness of a sample of Images and their indexing.

“Quality Control” means the procedural steps in place to provide confidence that the Image yields the same data as the Source Document.

“Record Authority” means the position designated in the RCRS as having authority over a particular Record Series.

“Record” means any record of information however recorded, whether by electronic means, in print form, on film or otherwise.

“Source Document” means any Document that has been captured.

“University Record” means a fixed unit of information in any format that documents a transaction, decision or relationship made by the University. It has continuing value in the future to complete further work, to provide evidence, to serve as institutional memory of obligations, responsibilities, decisions and actions, or to document the unique character and history of the institution.

Scope and authority

This Policy applies to any Document Imaging Program that destroys Source Documents and retains Images as Official Copies.

Other Document Imaging may continue with the understanding that destruction of Source Documents is not authorized except as part of a Document Imaging Program.

Any external Imaging service contracted by the University must conform to the requirements of this Policy and related documents in the Capture and storage of Images.

The University Secretary and General Counsel, or successor thereof, is the Policy Owner and is responsible for overseeing the implementation, administration and interpretation of this Policy.  


Document Imaging Programs at the University must be compliant with Canada General Standards Board 72.11 Microfilm and Document Images as Documentary Evidence (CGSB 72.11). This Policy provides authority to these programs as required by the standard and establishes principles to ensure the accuracy, completeness and trustworthiness of Images.

Roles and Responsibilities

  1. The Office of the University Secretary and General Counsel is responsible for developing institution-wide Procedures and Guidelines on Document Imaging. These documents are intended to guide Document Imaging Programs in the establishment of Local Procedures as required by CGSB 72.11 and this Policy.
  2. The Record Authority is responsible for authorizing Document Imaging Programs for the University Records under their purview and ensuring the creation of Local Procedures that comply with this Policy.
  3. Information Technology Services is responsible for providing and maintaining secure systems for Image storage and protection over time. The systems must allow Images to be retained according to the rules established in the Records Management Policy and the Records Classification and Retention Schedule. 

Authorization for Document Imaging Programs

  1. University departments, offices, services and faculties may establish Document Imaging Programs with the authorization of the Record Authority.

Destruction of Source Documents

  1. Source Documents may be destroyed as part of an authorized Document Imaging Program once the accuracy and completeness of Images have been verified. A record must be kept of the destruction of Source Documents.
  2. Images created by an authorized Document Imaging Program are deemed to be the Official Copies of University Records following the destruction of Source Documents.
  3. Source Documents may not be destroyed where contractual, legal or regulatory requirements dictate that an Image is not an acceptable format for retention of the Record.

Features of a Document Imaging Program

  1. Images must provide a complete and accurate reproduction of Source Records.
  2. Imaging will be conducted in the usual and ordinary course of business according to written, authorized Local Procedures.
  3. Capture, indexing, and destruction of Source Documents must be completed within a reasonable time-frame after the creation or receipt of Source Documents.
  4. Quality Control is paramount to establishing the accuracy, reliability and trustworthiness of Images. Quality Control requires:
    1. Operating according to established Local Procedures.
    2. Keeping a record of all activities, including Capture, Indexing, storage, modifications and destruction.
    3. Verifying the completeness of capture, indexing, and ensuring that any modifications do not alter the content or interpretation of the Source Record. A record must be kept of these Quality Control activities.
  5. Any changes to format must avoid altering the content of the Source Record.
  6. Storage, retention and protection of Images must be in accordance with Records Management Policies and Procedures.

Written Procedures Manual

  1. Written Local Procedures must be developed and authorized for any Document Imaging Program.
  2. Local Procedures must be kept up to date at all times. Any modification to procedures must be documented and approved before it is carried out.
  3. Local Procedures must include:
    1. A listing of the types of Documents authorized for imaging and storage.
    2. A listing of the types of Source Documents authorized for routine destruction and those which are not authorized for destruction due to identified requirements.
    3. Criteria for Quality Control.
    4. Standards for timeliness of operations.
    5. Description of systems and equipment.
  4. Local Procedures must include procedures for:
    1. Capture.
    2. Indexing.
    3. Quality Assurance.
    4. Certification and registration.
    5. Disposal of Source Documents.
    6. Protection of Images
    7. Applying record retention and disposition rules to Images.
  5. Procedures must conform to the requirements of CGSB 72.11-93.

Monitoring and review

This policy will be reviewed as necessary and at least every three years.  The University Secretary delegate is responsible to monitor and review this Policy.

Relevant legislation

Canada Evidence Act, RSC 1985, c C-5

Related policies, procedures & documents

Canada General Standards Board 72.11 Microfilm and Document Images as Documentary Evidence

Document Imaging Procedures 

Model procedures manual for Document Imaging Programs

Records Management Policy

Records Retention and Classification Schedule 

Records Disposition Procedures