Electronic Document Storage


Here’s a question I was asked recently.

“If I scan my source documents can I destroy the paper copies?”

The following information comes from the Canada Revenue Agency circular titled Books and Records Retention/Destruction.

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20.  Imaging and microfilm (including microfiche) reproductions of books of original entry and source documents have to be produced, controlled, and maintained according to the latest national standard of Canada, as outlined in the publication called:

Microfilm and Electronic Images as Documentary Evidence (CAN/CGSB-72.11-93).

These standards are available from:

Canadian General Standards Board

Mailing address:

Sales Centre
Canadian General Standards Board
Gatineau, QC K1A 1G6

Street address:

Place du Portage Phase 3, 6B1
11 Laurier Street
Gatineau, Quebec

Telephone number:

Ottawa Area

(819) 956-0425

or

Toll free from the rest of Canada:

1-800-665-2472

Fax number:

(819) 956-5644

E-mail:

ncr.cgsb-ongc@pwgsc.gc.ca

21.  An acceptable imaging program as explained in the Canadian General Standards publications mentioned in paragraph 20 requires that:

(a) a person in authority within the organization has confirmed in writing that the program will be part of the usual and ordinary activity of the organization’s business;

(b) systems and procedures are established and documented;

(c) a logbook is kept showing:
   • the date of the imaging;
   • the signatures of the persons authorizing and performing the imaging;
   •a description of the records imaged; and
   •whether source documents are destroyed or disposed of after imaging, and the date a source document was destroyed or disposed of;

(d) the imaging software maintains an index to permit the immediate location of any record, and the software inscribes the imaging date and the name of the person who does the imaging;

(e) the images are of commercial quality and are legible and readable when displayed on a computer screen or reproduced on paper;

(f) a system of inspection and quality control is established to ensure that c), d), and e) above are maintained; and

(g) after reasonable notification, equipment in good working order is available to view, or where feasible, to reproduce a hard copy of the image.

22.  Paper source documents that have been imaged in accordance with the latest national standard of Canada (see paragraph 20), may be disposed of and their images kept as permanent records.

23.  The taxpayer is responsible for ensuring that the imaging is done in an acceptable manner when the imaging has been done by a third party.

Retention period

24.  Books and records have to be kept for the period or periods provided by subsections 230(4) to (7) and section 5800 of the Income Tax Regulations or until the Minister gives written permission for their disposal.  Failure to comply with this requirement could result in prosecution by the CRA.

25.  Subsection 230(4.1) of the Act requires every person who keeps records electronically to retain them in an electronically readable format for the retention period outlined in subsection 230(4).

26.  Under the Act, books, records, and their related accounts and source documents, other than those referred to in paragraphs 27 and 28 below, have to be kept for a minimum of six years from the end of the last tax year to which they relate.  The tax year is the fiscal period for corporations and the calendar year for all other taxpayers.

Under the Employment Insurance Act and Canada Pension Plan , the retention period begins at the end of the calendar year to which the books and records relate.

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Paragraph 22 says the answer is yes, provided you comply with the conditions in paragraph 21.

I have not had a chance to view the standards guide to determine what an acceptable imaging program is and you might want to investigate that before proceeding.

© Rigel Chiokis 2012 - 2017