Cassio DeSanctis drafted this outline based on the procedural directive.

• Evaluation
  • Scoping Document
  • Business Plan
    • Justification for electronic signature (ES)
    • ES Process and Implementation Requirements
    • Risk Assessment
      • Define set of possible damaging events
      • Determine impacts of plausible damaging events
      • Determine probability of potential occurrence of events
    • Cost/Benefit Analysis
      • Costs from Potential Risks
        • Inconvenience, distress, damage to standing or reputation
        • Financial loss
        • Agency liability costs
        • Harm to agency programs or public interests
        • Impact from unauthorized release of sensitive information
        • Threats to personal safety
        • Civil or criminal violations
      • Operational Costs (Short and Long-term)
        • Hardware
        • Software
        • Administration
        • Support
      • Benefits
        • Transaction speed
        • Customer satisfaction and participation rates
        • Transaction completion rates
        • Improved record keeping / data analysis
        • Employee productivity / product quality
        • Information benefits to the public
        • Improved security / authentication process
    • Implementation Plan
      • Timeline
      • Milestones
      • Staffing
  • Office Management Approval
  • Implementation

Assuming that the evaluation results in a decision to implement:

• Implementation
  • Determine Assurance Level (AL) to Mitigate Risks
    • Use table of Potential Impacts/Probability of Occurrence
      • Choose lowest level that can mitigate risks
      • Use best judgment to determine appropriate AL
    • Identify and Implement Technical Requirements corresponding to AL
      • Level 1: allows PINs + challenge-response authentication
      • Level 2: strong password (no PINs) + tunneled pwd authentication
      • Level 3: one-time password device + PoP authentication protocol
      • Level 4: hard-tokens + private key PoP authentication
  • Legally Bind Transaction to Individual / Entity
    • Ensure submitting party knows "Terms and Conditions"
    • Establish that submitting party is aware of obligations they are agreeing to (e.g. permits/logbooks)
    • Make party take willful action to indicate desire to sign
  • Chain of Custody Audit Trails
    • Integrity of the transaction
      • Record sending location
      • Record sending individual / entity
      • Date and time stamp of receipt
      • Proof that agency sent a receipt
      • Confirmation that individual received the "receipt"
    • Handling of information once received
      • Changes to information requires the re-collection of all information that are part of the audit trail in the original document
      • Original documents should not be deleted when changes are made
      • Changes to information must be tracked including the person making the change, time stamp and accompanying documentation
    • Electronic Receipts
      • Should be printable
      • Indicates parties in the transaction and the agreement that was made
      • Contains confirmation code that can be used in the future to locate receipt
      • Requires audit trail to track that receipt was sent and received
    • Use of Information
      • ES should only be required when needed
      • Should not collect more information than necessary
      • User should be able to opt out to a paper process
      • Inform users that information collected will be managed and protected under Privacy Act, Computer Security Act, etc
    • Long-term Retention
      • Must meet requirements of Federal Records Act and NARA's Record Mgmt Guidance for ES
      • Permanently retained records must include the printed name of the signer and date of signature
      • Plan for software obsolescence / migrations to newer version without affecting existing documents
    • Review and Re-evaluation of ES Process
      • Should be included in the implementation strategy
      • Review quality indicators such as number of transactions, average completion time, resubmissions, etc
      • Evaluate opportunities from changes in technology