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Committee advances electronic records and signatures policy after removing hard-copy PIN log requirement
Summary
The committee moved Policy 303 (electronic/digital records and signatures) to the full board for first reading after agreeing to several edits, including removing an optional requirement for a hard-copy log of PINs/passwords and moving applicability language into the purpose section.
The Concord School District policy committee voted March 31 to send a draft electronic records and signatures policy (Policy 303) to the full board for first reading after a short review and several targeted edits.
District staff told the committee the draft is based largely on New Hampshire School Board Association model language and that technology and HR staff had reviewed it. The committee asked staff to move the "applicability" paragraph into the purpose section so the policy clearly covers communications with parents or guardians, FERPA-eligible students, district employees and volunteers, board members and vendors. Committee members also proposed editorial edits and a correction to refer to the board "president" rather than the "chair."
A focal point of discussion was a provision (page 2, item 3 in the draft) that asked the superintendent, "to the extent practicable," to implement a secure hard-copy log of PINs/passwords or actual signatures for any individual authorized to sign electronically on behalf of the district or school board. Several members, including Karen Meeker and board members, expressed concern that requiring a hard-copy PIN/password log would create an unnecessary maintenance burden and potential security risk. Committee members and staff agreed the district's data governance and security plan (an existing document) should remain the controlling standard for authentication and that the optional hard-copy log language should be removed from the policy.
Committee members also discussed the operational experience of using electronic signature tools (district staff noted DocuSign as an example), multi-factor authentication and that some documents commonly signed electronically include individualized education program (IEP) records and 504 plans, permission slips and business contracts. The committee asked staff to incorporate the suggested edits, remove the optional PIN/password log requirement, rename the board role in the draft to "board president," and return the revised policy in the board packet. With those caveats, the committee voted to send Policy 303 to the full board for first reading.
The motion to move Policy 303 to the full board for first reading was seconded by Barbara Higgins and passed by voice vote.
