Dear Project Promoter,
Retention of Audit Trail in the absence of wet signatures
With COVID-19 restrictions remaining in place it may not always be possible to obtain wet signatures on Performance and claims related documentation. As we approach the end of Year 4 Q1 when records created in this period will be verified, Projects are reminded that that in the absence of wet signature projects must retain an audit trail confirming that the details contained on this documentation have been agreed by participants and/or project staff.
It may not always be possible to have the PTP signed by the Project and the participant, in these instances PTP’s without wet signatures must be supported by an e-mail from the participant that clearly states that they confirm the details provided for the PTP are true and accurate. The e-mail should be uploaded to the ESIF database alongside the PTP. This procedure also applies to IRI and LTRI declarations which are signed by participants.
When e-mail communication is not an option Projects should upload alternative evidence to support how the PTP was completed. This could be a declaration from the Project which confirms how and when the details were gathered or a screenshot of the exchange between the participant and the Project.
Employment contracts for new and existing staff without wet signatures must also be supported by e-mail confirmation from the staff member that the details contained within their contract provide a true and accurate description of their agreed conditions of employment.
Performance and Claims documentation form part of your organisation’s on-the-spot checks and are a critical component to the integrity of the Claims made to the commission.
In accordance with Article 140 CPR, you must also ensure that all documents relating to each operation, its implementation and financing are retained until 31 December 2030 or otherwise instructed by the Managing Authority. However, Projects must securely dispose of all hard copies of documents when they upload them to the ESIF database.
If you have any queries on this please send them to firstname.lastname@example.org
ESF Programme Delivery Branch