112 - V1.0 - PAR - Site Visit and Remote Audit Requirements
112 - V1.0 - PAR - Site Visit and Remote Audit Requirements
112 - V1.0 - PAR - Site Visit and Remote Audit Requirements
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SUMMARY1
This document guides project developers and Validation/Verification Bodies (VVBs)
on:
⎯ The audit events within the project cycle where, as part of the audit process, a
physical site visit is required and where remote audits can potentially be carried
out. (Minimum physical site visit requirements)
⎯ Requirements for all audits
⎯ Requirements for audits using remote audit techniques
1
Please note that the requirements below supersede the summary should there be any discrepancy between the two.
Physical site visits are required within 2 years of the project start date and thereafter
every 3 years. All other validations and verifications may be carried remotely, should
the following conditions be met:
⎯ Remote audit techniques may be used, if deemed viable by the VVB, in any audit,
even if it includes a site visit
⎯ All audit techniques used, remote or not, are to be reported as part of the
validation/verification report, using the corresponding Audit Techniques Template.
BACKGROUND
With the advent of significant technological advances, Information and Communication
Technology (ICT) is becoming more sophisticated. It offers an opportunity to optimise
audit/assessment effectiveness and efficiency and to support and maintain the
integrity of the audit/assessment. Gold Standard believes that based on its recent
experience during the COVID-19 period, remote audit techniques offer an alternative
means to physical visit and demonstration of evidence. Conformity or traceability can
be confirmed via electronic means to facilitate remote audits/assessments.
The remote audit techniques involve the integration of suitable technology such as
smartphones, handheld devices, laptop - desktop computers, drones, video cameras,
wearable technologies and others for gathering, storing retrieving, processing,
analysing and transmitting information for auditing/assessments both locally and
remotely.
Remote audit techniques provide Validation/Verification Bodies (VVB) an alternative
pathway to facilitate the same level of assessments and offers an opportunity to
witness and assess more locations and increase capability with a similar amount of
resources used for on-site assessments, thereby possibly improving the reliability and
effectiveness of the assurance process.
Therefore, the Gold Standard will progress towards mainstreaming remote
assessments and audit techniques as credible alternatives to complement physical site
visits. Mainstreaming of remote audit and audit techniques are expected to provide
the following benefits to project developers and VVBs (as applicable):
TABLE OF CONTENTS
SUMMARY __________________________________________________________ 1
BACKGROUND _______________________________________________________ 2
1| SCOPE AND APPLICABILITY _______________________________________ 4
2| DEFINITIONS ___________________________________________________ 5
3| MINIMUM PHYSICAL SITE VISIT REQUIREMENTS ______________________ 6
4| REQUIREMENTS FOR ALL AUDITS ___________________________________ 6
5| REQUIREMENTS FOR AUDITS USING REMOTE AUDIT TECHNIQUES _________ 7
6| REMOTE AUDIT PROCEDURE & GUIDELINES __________________________ 10
7| FURTHER READING AND REFERENCES ______________________________ 13
ANNEX 1 - RISK ASSESSMENT GUIDELINES _______________________________ 15
ANNEX 2 – TECHNOLOGY/ELECTRONIC MEANS FOR REMOTE ASSESSMENT/AUDIT 16
ANNEX 3 – AUDIT TECHNIQUES CHECKLIST _______________________________ 18
1.2 | Applicability
2| DEFINITIONS
a. Audit instances/events: Audit instances/events refers to validation and
verification events that a VVB is engaged to assess.
b. Remote audit/assessment: Remote audit refers to the use of Information and
Communication Technology to gather information, interview an auditee, etc.,
when “face-to-face” methods are not possible or desired. (ISO 19011)
c. For this document, the remote audit/assessment refers to validation and
verification by VVB from a location other than being physically present at the
project site. The remote assessment may involve use of Information and
Communication Technologies for auditing/assessment purposes. The remote
assessment may also involve a hybrid approach involving on-site measures to
verify compliance with the requirements. In such cases, the VVB may appoint
an individual expert or audit team member to help lead auditors to verify
practices on the ground by facilitating data/information collection, transfer, and
verification using technology/electronic and other means, e.g. interviews,
videos, videos, photos, surveys, etc.
d. Remote audit techniques: Auditing techniques applied to validate/verify aspects
of a project without the validator/verifier being physically present at the project
site. These include phone calls, video calls, video recordings, geolocation data
and geoinformation systems, etc. They may be used in remote audits as well as
in audits involving a physical site visit.
e. Information and Communication Technology (ICT): also referred to as
“technology” in this document. Technologies – including, but not limited to,
software and hardware such as smartphones, handheld devices, laptop
computers, desktop computers, drones, video cameras, wearable technology,
artificial intelligence, and others. The use of ICT may be appropriate for
auditing/assessment both locally and remotely. Examples of the use of ICT
during audits/assessments may include but are not limited to:
⎯ Meetings; by means of teleconference facilities, including audio, video and
data sharing
⎯ Audit/assessment of documents and records by means of remote access,
either in real time or asynchronously
⎯ Recording of information and evidence by means of still video, video or audio
recordings
⎯ Providing visual/audio access to a remote location
2
For rules on possible deviations from the minimum site visit requirements, please see the
Rule Update “Applicability of minimum site visit requirements by VVB”
3
For micro-scale project internal validation/verification, SustainCERT acts as a VVB.
4
For example:
- if a retroactive project's start date is 1 year before submission for preliminary
review, the project has 1 more year (total of maximum 2 years from the start date)
to undergo an audit with a physical site visit.
- If a project is greenfield, i.e. it is not implemented at the time of validation, the
first site visit may be done during first verification, and not during validation, if all
aspects of the validation can be audited remotely.
4.1.3 | Remote audit techniques may be used as appropriate, and applying the
safeguards and procedures in this document, in any audit, whether it includes
a physical site visit or not. See ANNEX 2 – TECHNOLOGY/ELECTRONIC MEANS
FOR REMOTE ASSESSMENT/AUDIT
4.1.4 | The VVB, in its audit report, shall include the template referenced in ANNEX 3
– of this document to report on:
a. the auditing techniques used in each audit, for each aspect of the project
b. the assessment of the appropriateness of the selected auditing techniques
c. any mitigation measures implemented to reduce risks associated with the
auditing techniques
d. any aspects of the project that need to be further audited during the
following audit (Forward Action Requests)
4.1.5 | Gold Standard reserves the right to enforce a mandatory site visit before
concluding the design and or performance review, should material issues 5 be
identified with the use of remote auditing techniques during an audit. Such a
site visit:
a. may be of a limited scope, covering only the material issues identified
b. shall be conducted by a Gold Standard-approved validator/verifier and
may not be outsourced to a local expert.
5
Material issues include, among others, non-conformity with the present requirements: frequency, risk assessment,
team structure and competence, adequacy of remote audit techniques employed, etc.
5.1.3 | VVB shall document evidence of such agreements. This evidence could be
recorded, agreed on procedures, or emails. The importance resides in having
these criteria acknowledged by all participants.
5.1.4 | Measures to ensure confidentiality and security shall be confirmed during first
interaction, i.e. meeting calls and maintained throughout remote
audit/assessment activities.
5.1.5 | In the case of non-fulfilment of these measures or non-agreement of
information security and data protection measures, the VVB shall use other
methods to conduct the remote assessment.
5.1.6 | If sufficient information cannot be obtained via application of the
technology/electronic means and required information is necessary for VVB to
form a conclusion with the planned audit techniques, the VVB may use other
technology/electronic means or expand the scope/sample of the assessment
until sufficient information is obtained. If expanding the scope of the audit is
not sufficient, the VVB shall:
a. Repeat the assessment at another time when e.g. the
connection/conditions allow the VVB to conduct the assessment
b. Carry out a physical site visit, within the same audit process, covering at
least the aspects not sufficiently audited by remote techniques.
c. Discontinue the audit (do not issue a validation/verification opinion) and
re-start the audit with a new set of planned techniques, including a
physical site visit.
5.2.1 | An audit team that conducts the remote assessment shall meet the structure
and competence requirements as outlined in the Validation & Verification Body
Requirements.
5.2.2 | When using ICT, VVB and other involved experts (e.g. drone pilots, technical
experts) shall have the competency and ability to understand and utilise the
information and communication technologies employed to achieve the desired
results of audit(s)/assessment(s). The auditor/assessor shall also be aware of
the risks and opportunities of the information and communication
technologies used and the impacts that they may have on the validity and
objectivity of the information gathered.
5.2.3 | The VVB may engage individual experts and/or external individual(s) for
remote assessment following the requirements outlined in section 7.5.2 of
VVB requirements.
5.2.4 | When an individual expert/external individual is involved, the VVB must
ensure that the expert/individual has
a. no financial interest or any other conflict of interest concerning the Project
b. a non-disclosure agreement covering the project audited
5.2.8 | The VVB audit team shall provide individual expert/external individual training
on, as a minimum:
a. Project-specific and relevant standard-specific requirements,
b. Interview techniques
c. The information to be collected on-site,
d. The reporting format,
e. The channel of communication through which information shall be
transferred from while on-site and during the future course of exchanges.
5.2.9 | The individual expert/external individual shall collect and report information in
the prescribed format/checklist by audit team and present it to the auditing
team (team leader and technical expert). The VVB shall keep said report in
records and shall provide a copy to Gold Standard if needed.
6.1.1 | Remote assessments (those that do not include a physical site visit by an
auditor) provide the opportunity to optimise audit/assessment effectiveness
and efficiency while maintaining the integrity of the audit/assessment
process. The objective of a remote assessment is to establish the level of
confidence in the VVB certification process by direct observations carried out
through an electronic medium.
6.2 | Agreement
6.2.1 | The use of remote assessments by VVB of a given project may be requested
by the project developer for its assessment needs (validation, verifications,
etc.) when a physical site visit is not mandatory or feasible, and where the PD
and the VVB consider a remote audit feasible for the project’s context.
Remote audit is at the discretion of the VVB, who is entitled to reject any
request from project developers to consider it as an option.
6.3.1 | The VVB may consider a project developer's request for a remote
audit/assessments following the below listed qualifying criteria:
6.3.2 | A minimum physical site visit is not mandated as per GS4GG requirements or
not required/recommended as per VVB’s previous audit findings.
6.3.3 | The VVB can create a feasible audit plan that covers all aspects of a project
design validation/project performance verification (as per ANNEX 3 – AUDIT
TECHNIQUES ) with suitable auditing techniques (as per ANNEX 2 –
TECHNOLOGY/ELECTRONIC MEANS FOR REMOTE ASSESSMENT/AUDIT.
6.3.4 | The VVB can perform a risk assessment according to ANNEX 1 - RISK
ASSESSMENT GUIDELINES and its own risk assessment procedure.
6.3.5 | The VVB is confident that any identified significant risk/issue can be
addressed and assessed/audited by the VVB using technology/ electronic
means to attain reasonable level of assurance
6.3.6 | The VVB can confirm before the audit commences that:
a. The VVB and the project developer can provide representatives who are
capable of communicating proficiently in the same language.
b. The VVB has the capability and aptitude to conduct the remote assessment
in the chosen medium/forum.
c. The PD, including all interviewees, has the capability and aptitude to
undergo the remote assessment in the chosen medium/forum.
d. A list of activities, areas, information and personnel to be involved in the
remote assessment is available.
e. The infrastructure required for the chosen auditing techniques/media as
well as secure data storage is available.
f. A confidentiality agreement is in place between the VVB and the project
participants, and the remote audit does not contradict any confidentiality
agreements between the project participants.
g. In case of a verification audit, the project developer has implemented the
registered monitoring plan and has a data management system where
records, data, etc. and can be audited remotely.
6.5.1 | Should the VVB not be able to review any aspect of the project or make a
complete determination, the VVB should make a record of this aspect and the
related issues.
6.5.2 | The assessment should be carried out in quiet environments whenever
possible to avoid interference and background noise (i.e., speakerphones)
6.5.3 | Facilitation of the assessment should follow normal assessment plans and
processes.
6.5.4 | Both parties should make their best effort to confirm what was heard, stated
and read throughout the assessment.
6.5.5 | All remote assessments should be concluded with a summary, review of the
day(s)’s events, issues of concern, clarification of issues, nonconformances
and expectations.
6.5.6 | The VVB may terminate the assessment prior to the schedule due to an
inability to maintain good connections or conditions during the scheduled
time. This should be recorded in the assessment report.
6.5.7 | The VVB & project developer should take appropriate measures to safeguard
the confidentially of data in any format. The audit team should prevent the
access and retention of more documented information than it would in a
normal face to face audit. The audit team will probably want to have access to
more information to prepare for the audit or to have the ability to analyse
documented information asynchronously. When documented information is to
be analysed in an asynchronous manner, it is a good practice that it should be
shared in a secure and agreed system, such as cloud-based, Virtual Private
Network or other file-sharing systems, utilising confidentiality and data
privacy guidelines. Once the audit is complete, the auditor should delete from
its system or remove access to any documented information and records not
required to be retained as objective evidence.
6.5.8 | Any screenshots of documents or records or other kind of evidence that the
auditor/individual expert takes should be previously authorised by the project
developer and participants.
For Validations:
a. Any project aspect that might cease to exist after validation, e.g. the
baseline technology.
For Verifications/Renewals
Remote auditing
S.No. Potential use
means/methods
6
The VVB should review the appropriateness of conducting interviews remotely in the cultural and technological
context of the project. Very often, stakeholders and end users of the technology may feel intimidated by conducting
interviews online or on the phone, which may limit the ability of the auditor to assess key aspects of the project.
Careful selection of appropriate methods by the VVB according to the is required, in consultation with the Project
Developer and/or local experts.
(e.g., drone, video call, Ability to view high risk; processes or operations
live stream etc.) (not easily accessible)
Witnessing running operations (at a
facility/plant)
DOCUMENT HISTORY
Version Date Description
0.9 07/28/2021 Version for Public Consultation