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Sample procedural documentation for substitute scanning, published by the German Federal Chamber of Tax Consultants (BStBK) in cooperation with the German Tax Consultants Association (DStV). (DStV)
What does procedural documentation say?
That everything is running according to plan
With the help of procedural documentation, companies can prove that their IT-supported accounting and the storage of data and documents comply with the principles of regularity defined in GoBD.
For this purpose, it describes in detail how vouchers and documents are recorded, received, digitized, processed, issued and stored. The taxable user of the IT solution used, or the entrepreneur himself, is responsible for creating procedural documentation.
That you can provide any document on request
The aim is to make accounting and archiving documents in the company understandable and verifiable within a reasonable time for an expert, for example in the course of an audit.
What should procedural documentation take into account?
Clearly structured procedural documentation should be available for every IT system. The content, structure and results of the IT process should be completely and convincingly obvious.
To verify traceability, comprehensive and up-to-date procedural documentation is required that documents all system and technological changes in terms of content and time without any gaps.
A procedure documentation describes the intended organizational and technical process. From the origin of the information to indexing, processing and storage as well as unambiguous retrieval.
The procedural documentation should also show how electronic documents are captured, processed, issued and stored.
A description of the data backup procedure, which is integrated in PaperOffice in case of local database application, is also an important part of a procedure documentation.
PaperOffice complies with GOBD through certification as well as testing of all software requirements by meeting all required standards.
PRINCIPLE OF TRACEABILITY AND VERIFIABILITY (GOBD CHAPTER 3.1)
According to the GoBD, the taxpayer is obliged to ensure that the IT system is secured against loss (e.g. untraceability) and protected against unauthorized entries and changes.
PRINCIPLES OF TRUTH, CLARITY AND CONTINUOUS RECORDS WITH THE INDIVIDUAL SUBJECTS (GOBD CHAPTER 3.2)
DMS server components are generally subject to the same security requirements as other IT components. Relevant topics are monitoring and data security.
COMPLETENESS (GOBD CHAPTER 3.2.1)
As a matter of principle, each document that must be retained must be recorded individually and with all its components (completeness and completeness of gaps).
CORRECTNESS (GOBD CHAPTER 3.2.2)
Following the principle of correctness, the DMS must ensure that the documents and data to be archived have the required degree of conformity with the original (in terms of image or content).
ORDER (GOBD CHAPTER 3.2.4)
The principles of orderly accounting when using a DMS are considered to be consistently met if compliance with the orderliness criteria can be ensured throughout the entire retention period.
UNCHANGEABILITY (GOBD CHAPTER 3.2.5)
The GoBD require that the data processing procedure used must be designed in such a way that all information which has entered the processing procedure may no longer be suppressed or overwritten, deleted, changed or falsified without being identified (GoBD chapter 3.1; margin no. 58-60).
Who helps with process documentation?
If you have absolute confidence in your own processes, you can probably get by without a tax advisor. However, we recommend getting help from a tax advisor in advance or at least once during the creation of the process documentation.
From our own experience, it is always advisable and helpful to speak openly with the auditing body, because despite all the specifications and standards, it is ultimately the auditor who decides.
Who approves the process documentation?
Beware of marketing half-knowledge: Certificates of any kind and from any issuer are not accepted by the tax authorities! In case of need, the only thing that counts is the presentation of the procedural documentation according to GoBD and whether everything really fits is decided by the auditing body, e.g. your tax auditors or tax office.
Why is not only PaperOffice sufficient?
Explained briefly and succinctly: If, for example, you have archived an invoice in PaperOffice in a legally secure and audit-proof manner, the invoice may nevertheless have been manipulated or changed BEFORE it was scanned.
You may be saving in an audit-proof manner, but the overall process itself is not audit-proof and therefore does not comply with GoBD.
Can I throw away original documents?
Documents with legal relevance, for example contracts, must still be kept in the original. To put it in a nutshell: The tax office accepts electronic documents, but the court only accepts originals in the event of a dispute. This is due to the fact that a signature can only be checked for authenticity on original documents. We recommend never throwing away originals.
Why can I delete PaperOffice documents?
Again, there is the process documentation. Because it is technically impossible to completely exclude deletion as long as the data is stored with you. In the end you can delete the record yourself directly from the database. Or remove the hard disk. Or dispose of the server. Or blow up the building.
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* Use of PaperOffice®, PaperOffice® API, PaperOffice® Online API or PaperOffice® components in third-party software