IFS 3.3.3 - What is acceptable as a training signature?

Hello 

 

IFS 3.3.3 regarding training says that records of training shall include list of participants (including their signature). For the moment we use paper records were people just sign off by hand.

 

However, we are in the middle of digitalization project and would also have training records in electronical form. When employee read the instruction would use his personal card with chip to click and confirm he get familiarized with the instruction.

 

That caused a discussion what signature is: would card click accepted as a signature?

 

I'm really curious your experience with such a matter.

 

 

Greetings Magnesowka,

 

Yes, you can by all means replace paper signature with any other form that can link someone to a certain event, as long as you describe it in your procedure. There are already ways for that.

Simplest I have seen is through google excel, were a trainee goes and checks "ok" through his personal credential (email) and then when you click in cell history it shows who was that made the change! More advanced is the way you want to do it or the sign box on a touch device were you can digitally sign off (finger or electronic pen). An even more advanced way is through biometric sign off like a fingerprint scan on a tablet (this was in a company with a "heavy" food defense system).

 

I mean come on, its 2023! Let's move past endless paper documentation...

 

Regards!

Thank you! I hoped it would be possible, thank you for your comments and we just move on into future :)

I'm all for getting into electronic record keeping, though I'm finding it usually runs more expensive than the executives want to puruse to do it right.

 

Only argument I can make for your described scenario is control of the cards themselves.  If an auditor can make a case that the cards can be accessed or used by the wrong employees (say they're all hanging on a hook during their shifts), then it leaves a potential gap you'll need to figure out how to address.  If they can find a situation where one employee scans the wrong card, accidentally or on purpose, then the program loses it's effectiveness.

Chipped cards will need to be highly controlled.

Speaking as an Auditor I found that this was an area where there was (never intentional) area of issues.

It may be better to continue with a sigmatures/ initials and printed name.

We actually got tripped up on this one duringba recent audit.

Interested to know how your trainees access the training, IE log into a PC to access the training? All of our training is conducted online and you have to log into the training module with your own unique login and password. These are then linked to the users profile. Once the training is completed and passed that's recorded in the training module, no need for signatures as the training is all electronically recorded and managed.

Chipped cards will need to be highly controlled.

Speaking as an Auditor I found that this was an area where there was (never intentional) area of issues.

It may be better to continue with a sigmatures/ initials and printed name.

We actually got tripped up on this one duringba recent audit.

Thank you for all your comments. We are currently working on efficient system training and that is why the question is asked. In terms of using someone else card: don't you think that in the same way we can look at the risk of one person signing off on the paper by another one? 

Signatures have their own shortcomings, but they’re historically more common and accepted. You’ll sometimes see auditors want you to have a list of people’s signatures on file (so they can compare them and look for obvious forgery). While not full proof, at least signatures can be hard to fake and detected after, whereas the cards can more easily be faked.

I can see problematic scenarios where a QA Manager just swipes all of the employee cards alone in a backroom to claim all employees sat for a training, vs it being much less likely a Manager tries to forge all their employee’s signatures.

But cards aren’t impossible. You’re just going to need a control program that can’t be shot full of holes by a creative auditor.

I would simply go to my training SOP. Update the section about signature and records as such" After the training is complete, employee will digitally sign by using his/her user ID, Physical signature on paper will no longer be needed".

 

Or you can work with your IT to authorize in document signature. Every time a training is complete the trainee will sign on tablet/a touch screen. Software's like DocuSign has more ease but might be a separate investment. 

 

You are audited for your procedures. You can make your procedures to meet your requirements, then, follow it and document it. It will meet IFS requirements as well.