Using Electronic Signatures in Performance Appraisal Programs
Using Electronic Signatures in Performance Appraisal Programs
When OPM deregulated performance management in 1995, we gave agencies as much flexibility as possible to use available tools and technology. Current regulations make it possible to develop a performance management program that would allow everything from plan establishment and progress reviews to the actual appraisal of performance to be recorded electronically.
Requirements
OPM's electronic signature requirements for performance appraisals are similar to those included in The Guide to Processing Personnel Actions for SF 50/52's and NIST FIPS 113. You can find the OPM requirements for SF 50/52's in chapter 3 of The Guide to Processing Personnel Actions. The requirements dealing specifically with electronic signatures are:
- the signal or symbol must be unique to the signer;
- the "signature" must be capable of being verified and must be linked to the data being transmitted, including the effective date;
- control features must be in place to insure the authenticity of data on the form, including the electronic signature; and
- such controls must provide reasonable assurance that deliberate or inadvertent manipulation, modification or loss of data on the electronically stored form is detected.
Security and Privacy of Sensitive Information
Congress established the Computer Security Act of 1987, which mandated that the National Institute of Standards and Technology (NIST) should establish minimum acceptable practices for the security and privacy of sensitive information stored in Federal computer systems. Of course, as with any sensitive document, an agency must take appropriate measures to ensure the security of the performance appraisals and the privacy of the individuals involved. GSA regulations include additional information on the storage and maintenance of electronic records. (These regulations are located in section 201-45.2 of title 41, Code of Federal Regulations.)
The NIST Federal Information Processing Standard (FIPS) 113, which is available online at http://www.itl.nist.gov/div897/pubs/fip113.htm, includes information on the establishment and use of authentification codes. These codes are unique to individuals and ensure that the document was "signed" by the appropriate person.
Background on electronic signatures
As early as 1951, the Federal Government recognized that a signature did not have to be handwritten and that "any symbol adopted as one's signature when affixed with his knowledge and consent is a binding and legal signature." (Comptroller General (CG) Decision B- 104590, September 12, 1951.)
Although not directly related, another very important CG decision affects the ability to use electronic signatures in performance management processes. In 1991, NIST asked for a decision regarding whether or not Federal agencies could use Electronic Data Interchange technologies to create valid contractual obligations that can be recorded consistent with the documentary evidence requirement for Government obligations. In a CG decision (B-245714 dated December 13, 1991), the CG concluded that valid obligations could be made using computer technology. The results of this decision regarding contracts also can be applied to valid performance plans and appraisals.
Items to remember.
Although excited about the possibilities offered by a "paperless" appraisal process, we remind appraisal program designers that:
- communication is still one of the most important factors in the performance management process;
- face-to-face progress reviews and appraisal discussions lead to more effective performance management, and
- a hard copy of the "signed" appraisals for the three most recent ratings of record must be in the employee's Official Personnel Folder when the employee leaves an agency.