Lesson 3: System Description(s)
The System Description component documents how the system(s) meet the CROMERR standards.
To help applicants complete this description, EPA has developed a CROMERR System Checklist Template and strongly encourages you to use it. The template reflects the Checklist Requirements Roadmap, which lays out the CROMERR standards as a list of 20 performance-based system requirements. These requirements are divided into five categories: Registration, Signature Process, Submission Process, Signature Validation, and Creation of the Copy of Record As defined in § 3.3 of CROMERR, a true and correct copy of an electronic document received by an electronic document receiving system, which copy can be viewed in a human-readable format that clearly and accurately associates all the information provided in the electronic document with descriptions or labeling of the information. A copy of record includes: 1) All electronic signatures contained in or logically associated with that document; 2) The date and time of receipt; and 3) Any other information used to record the meaning of the document or the circumstances of its receipt. (COR As defined in § 3.3 of CROMERR, a true and correct copy of an electronic document received by an electronic document receiving system, which copy can be viewed in a human-readable format that clearly and accurately associates all the information provided in the electronic document with descriptions or labeling of the information. A copy of record includes: 1) All electronic signatures contained in or logically associated with that document; 2) The date and time of receipt; and 3) Any other information used to record the meaning of the document or the circumstances of its receipt.).
The descriptions that an applicant provides for each of the 20 checklist requirements reflect how the applicant's system(s) will meet the CROMERR standards. When applicable, supporting documentation should be attached to the descriptions. Such attachments may include the Electronic Signature Agreement As defined in § 3.3 of CROMERR, an agreement signed by an individual with respect to an electronic signature device that the individual will use to create his or her electronic signatures requiring such individual to protect the electronic signature device from compromise; to promptly report to the agency or agencies relying on the electronic signatures created any evidence discovered that the device has been compromised; and to be held as legally bound, obligated, or responsible by the electronic signatures created as by a handwritten signature., system users' guides, various process diagrams, system screenshots and/or printouts, and an example Copy of Record. The CROMERR standards are explained in Lesson 6. Lesson 7 then describes how the CROMERR standards are expressed as checklist requirements, and explains how to use the System Checklist Template.