AUTHORIZATION TO ACCEPT AND DISTRIBUTE ELECTRONIC RECORDS, TO USE ELECTRONIC SIGNATURE, AND MAKE ELECTRONIC FUND TRANSFERS | Policy Manual

6107 - AUTHORIZATION TO ACCEPT AND DISTRIBUTE ELECTRONIC RECORDS, TO USE ELECTRONIC SIGNATURE, AND MAKE ELECTRONIC FUND TRANSFERS

Electronic Records and Electronic Signatures

Unless a provision of law specifically prohibits the use of an electronic record for the specified purpose, the Board hereby authorizes the acceptance and distribution of electronic records and electronic signatures to and from District staff and other persons, as well as between District staff members. Additionally, the Board further authorizes District staff to create, generate, communicate, store, process, use, and rely upon electronic records and electronic signatures. The Superintendent shall put in place measures to protect the integrity, security, and accessibility of electronic signatures and electronic records to comply with the mandates of State and Federal agencies or programs, including Medicaid.

All District staff shall comply with all provisions of the Uniform Electronic Transaction Act when creating, generating, sending, communicating, receiving, storing, processing, using, and relying upon electronic records. Further, all District staff and other persons who use electronic signatures when completing transactions with the Board shall do so in compliance with State law.

The Superintendent shall consult with the State of Florida's Department of Management Services (Department) regarding the District's authorized acceptance and distribution of electronic records and electronic signatures. The Department may specify the following:

The manner and format in which the electronic records must be created, generated, sent, communicated, received, and stored and the systems established for those purposes.
If electronic records must be signed by electronic means, the type of electronic signature that is required, the manner and format in which the electronic signature must be affixed to the electronic record, and the identity of, or criteria that must be met, by any third party used by a person filing a document to facilitate the process.
Control processes and procedures as appropriate to ensure adequate preservation, disposition, integrity, security, confidentiality, and auditability of electronic records.
Any other required attributes for electronic records which are specified for nonelectronic records or reasonably necessary under the circumstances.

ELECTRONIC FUNDS TRANSFERS

Purpose

The purpose of this policy is to set forth objectives for the management and oversight of electronic funds transfers (EFTs) and refers to the movement of funds into, out of, and between District bank accounts. Electronic transfers include direct deposit, wires transfer, withdrawal, investment, automatic clearinghouse (ACH), or any other method that may be developed and implemented by financial institutions for the purposes of transferring funds between District accounts or between financial institutions on behalf of the District. Movement of District funds by electronic means shall comply with F.S. 668.

Internal Controls and Delegation of Authority

The oversight of the electronic funds transfers resides with the Chief Financial Officer (CFO), Director of Accounting Services and Accounting Manager. A system of internal controls and operational procedures has been established to manage the funds transfer process and the reconciliation of bank accounts. Staff will exercise internal controls and the separation of duties while performing the funds transfers and cash management functions. Independent auditors, as part of the District’s financial audits, will review the system of internal controls and compliance with the operational procedures and with this policy.

Scope

Board funds shall be electronically transferred for the following purposes:

receipt of Board revenue from local, State, and Federal sources;
settlement on investment transactions (e.g., purchases, sales, or principal and interest distributions);
transfers between Board accounts as needed for legitimate funds management activities;
payment of legitimate obligations, based upon legal or contractual requirements incurred in the course of Board business;
payroll and other employee direct deposit payments.

Outgoing Electronic Funds Transfers

Repetitive wire transfers are established by the Accounting Personnel, with the District’s financial institution, using secure banking software which is password protected. The initial wire setup is approved by the Director of Accounting Services or the CFO. After the initial setup, and approval, repetitive transactions are initiated by accounting personnel and approved by a Fund Accountant, Accountant I, Accounting Supervisor, Accounting Manager, or Accounting Director. Individuals performing these duties cannot be an initiator and approver of a single transaction.

Non-repetitive wire transfers are required on rare occasions and may occur between District accounts or funds may be transferred to a non-district account. Transfers may be initiated by accounting personnel but must be approved by the Director of Accounting Services or CFO, in writing, prior to the initiation of the transfer. Individuals performing these duties cannot be an initiator and approver of one transaction.

International wire transfers are allowed only for foreign trips or programs as specifically approved by the Board. The transfers will be initiated by Accounting Services personnel and approved by the Director of Accounting Services or CFO prior to payment initiation and will be based only on specific amounts approved by Board action. Individuals performing these duties cannot be an initiator and approver of one transaction.

ACH transactions are allowed for the following transaction types:

ACH debit transactions require funds to be retrieved from a Board bank account by the counterparty’s financial institution and are prohibited, unless the counterparty to the transaction is another governmental entity or the transaction is required by a Board approved contract. Other ACH debit transactions may occasionally occur for approved and legitimate bank fees for items such as bank checks and/or deposit tickets. These will be monitored by Financial Services staff.
ACH credit transactions require funds to be paid directly to an approved Board vendor’s bank account. ACH credit transactions may be paid when required based on contractual obligations or when this method of payment is advantageous to the Board.
Direct deposit payments of employees’ wages or other direct payments will be initiated by payroll/accounting personnel in compliance with established accounting procedures.
Individuals performing these duties cannot be an initiator and approver of one transaction.
Other outgoing electronic funds transfers as established by the District’s financial institution may be permitted, as long as transfers follow similar procedures as outlined above.