Request for Access form - RTR

[steveburtch]

Currently we have a request for access form for director search. We will need either and updated or new form (or forms) to allow competent authorities to request access to the beneficial owner / director search

Process is intended to mimic what is done for director search

• separate form or add to director search form (check with Wendy Flynn's team)
• requests for this are processed through BC Online Administration

Current director search Request for Access form: https://drive.google.com/file/d/18vqK0SDB198PjwLaEMsanQjKQgZg_b2w/view?usp=sharing

Bill 20 https://www.leg.bc.ca/parliamentary-business/legislation-debates-proceedings/42nd-parliament/4th-session/bills/progress-of-bills BC Corp Act https://www.bclaws.gov.bc.ca/civix/document/id/complete/statreg/02057_00

From Bill 20, Use and Disclosure

2) Enforcement officer and Ministry of Finance, full access for the following situations: a. An enforcement officer may search and inspect the registrar’s transparency register for the purposes of determining compliance with Part 4.1, Part 11.1, Divisions 3.2 and 3.3 of Part 12 and the regulations. b. An official or employee of the ministry may search and inspect the registrar’s transparency register for any of the following purposes: i. compiling statistical information; ii. formulating or evaluating government policy; iii. prescribed purposes.

3) Tax Authorities, full access for the following situations: a. Administering or enforcing i. A law in BC or Canada that provides for the imposition or collection of a tax, royalty or duty ii. A prescribed law of BC or Canada that is related to a law referred to in subparagraph (i) b. Providing information to another jurisdiction in or outside Canada to assist in the administration or enforcement of a law of that jurisdiction that provides for the imposition or collection of a tax, royalty or duty, if the assistance is authorized under an arrangement, written agreement, treaty or law of BC or Canada

4) Law enforcement, full access for the following situations: a. Conducting an investigation that is undertaken with a view to a law enforcement proceeding or from which a law enforcement proceeding is likely to occur b. Policing and criminal operations in Canada c. Assisting another law enforcement agency in Canada for purposes described in subsection (a) or (b) d. Providing information to a law enforcement agency outside Canada to assist in a law enforcement proceeding if authorized under an arrangement, written agreement, treaty or law of BC or Canada

5) Regulators, full access for the following situations: a. administering or enforcing a law for which the regulator is responsible b. assisting another agency in Canada in the administration or enforcement of a law that is similar to a law for which the regulator is responsible; c. providing information in the registrar’s transparency register to an agency outside Canada to assist the agency in the administration or enforcement of a law that is similar to a law for which the regulator is responsible if the assistance is authorized under an arrangement, written agreement, treaty or law of British Columbia or Canada.

[mstanton1]

@Apt766525 when this is picked up I can set up a meeting with BCOL Admin led by Wendy Flynn so we can solicit input on the process.

[Apt766525]

@mstanton1 @steveburtch have created a draft of the access request form specifying the BILL 20 sections in it and also have tweeked the director search access request process flow for the access for beneficial owner search. Kindly please review the draft and the flow and let me know if any changes to be made before confirming with BCOL Admin.

Link to the access request form draft 1 - https://drive.google.com/file/d/17NFoLNI_oRKOrhwr2EKmkhWLTePBPqW0/view?usp=drive_link

Link to the access request process flow - https://drive.google.com/file/d/13FM3FDFipH4RaImITnMG1Ixqh9S8VhHC/view?usp=drive_link

[mstanton1]

Great work Avinash! I've added comments / questions below. Let's connect if you want to discuss these.

Request Form: It may be nice to make the box for the description of the Agency/Branch role at the end of page 2 slightly larger. Given the legislation that drives access let's provide Steve a few days to review, and once any feedback he provides is incorporated this could be sent to Julie and Samar for a review from a policy lens.

Process Flow:

• At the start it includes a box for competent authority. The flow may end up simpler to digest if rather than including the users within the boxes the different users were identified in swim lanes?
• As far as "Inquire about access to Beneficial Owner search and information about it" has there been discussion with @steveburtch or @magszymanski on where this information might live? If we could add more details on where a user is going to find information it'd be more clear. That also feeds into the call/email. Depending on where a user finds information the contact information they receive may vary. Some sites point users to Maximus or straight to BC Registries staff. Let's get a grasp on this information access point.
• For the box where BCOL Admin sends a rejection letter to the client are there existing outlook templates for Director Search or are they free form typing these letters? Let's get information so we can refine the block for how they send an item, and can carve off any additional tasks (e.g. templates) for our team
• There's a yellow box for when Access is granted per account. With director search is this done by BC Online staff or is this something that a technical team does? We need to know who is doing this and how that process works to understand if there is technical work. I believe director search had an ability for BC Online Admin to grant access within the UI?
• Is there any idea of how many groups may require this? Is the current thought it would be the same group who access director search? If so can we get a count of accounts with access? Kial likely could point us to the person who can pull that data

[magszymanski]

Hi folks - this form will have to follow the BC Registry standard, and we should leverage the Director Search format that was revised by the Digital Partnerships team. Revisions included updated FOIPPA disclaimer since the Act went through its own revisions and the section numbers. The current, updated form that is used by BCOL Admin for administering DS access is located on the LAN and I added it to Avinash's BA folder here. (Melissa - its LAN location is: R:\ARCS\Admin 100-499\Forms Mgmt 285\20 Forms Mgmt Active\Forms\REGISTRY Forms\20\COM forms\55COM\FORM 55 COM - Director Search Access Request.pdf)

Avinash - let me know if you want to meet over this.

[Apt766525]

@magszymanski @mstanton1 @steveburtch This is perfect Mags. Thanks for adding it to the BA folder. Will follow this format and create a draft. Just few clarifications: Does this statement hold good for BO search under instructions? - "If approved, agencies requesting access to Director Search will require a Premium BC Registries account to access the application." - Do we require a premium account for BO search?

I guess we can omit this in the case of BO search (Pls confirm) - "DID YOU PREVIOUSLY HAVE DIRECTOR SEARCH ACCESS?" and the "RACF ID".

[magszymanski]

Thanks for meeting me, Avinash. @mstanton1:

It would make sense to make BO Search available only to Premium accounts to follow the structure of Director Search and Business Search also only being available to Premium. This is because corporations will eventually move over and users will be able to seamlessly move from DS/BO Search into Business Search to do investigations. (Melissa, FYI: we made the process decision that the new Director Search would be available only to Premium accounts while Kial underscored that DS isn't technically restricted to Premium or Basic.)

Merging of accounts - getting rid of Basic/Premium accounts is on the radar for Relationships, though not sure when. OCM hopes it's in time for the corps migration to make the account creation process more friendly for users. If this happens, we will have to update the form.

Melissa We haven't discussed yet who will support BO requests - is it BCOL Admin, as they do today with Director Search authorization? If yes, they we should consult with them whether they would want to keep the questions about RACF ID and previous DS access - thought, as Avinash and I discussed, having DS does not automatically give an entity authorization to having BO Search, since they are covered by different acts.

[Apt766525]

@magszymanski @mstanton1 Have updated the access request form draft based on the conversation with Mags. https://drive.google.com/file/d/17NFoLNI_oRKOrhwr2EKmkhWLTePBPqW0/view?usp=drive_link

Link to the process flow: https://drive.google.com/file/d/13FM3FDFipH4RaImITnMG1Ixqh9S8VhHC/view?usp=drive_link

[Apt766525]

@mstanton1 Updated the flow as per your suggestion to swimlane. https://drive.google.com/file/d/1siE7AQzLoPEMitRTy2Q12M9frt8qpbZu/view?usp=drive_link

Link to the updated request form document: https://drive.google.com/file/d/17NFoLNI_oRKOrhwr2EKmkhWLTePBPqW0/view?usp=drive_link

[mstanton1]

@Apt766525 thanks for providing those updated documents. They are looking good.

@magszymanski thank you for information on the process decision to only allow Competent Authority search for Premium. At a portfolio level work is being reviewed so there can be support with prioritization of initiates such as the simplifying to only have one account type. We should have more information on timelines shortly. To your comment on whether BC Online Administration would handle this I'd made an assumption as their group specializes in accounts and access. I'll reach out to Wendy Flynn and Dwayne Gordon to confirm my understanding.

@Apt766525 @magszymanski as far as next steps, it would be great to review these with BCOL Admin after I have reached out to verify their role. They could likely also assist with some of the questions that are embedded into the Beneficial Owner Search Request process flow. Avinash - you will be key to go over what you've produced and document any other requirements that come from the meeting. Mags - do you want to participate in that as well?

[Apt766525]

mstanton1 Sure. Will do. Thanks

[magszymanski]

@mstanton1 Great! Yes, please to participating in BCOL Admin discussions, as they will aide in OCM activities as well.

I'm also working on a Change Impact Assessment right now, which looks at how groups are and will be impacted. I'm focusing today on Current State (since BO filings will be net new, most groups today do not have a "current state" process) and I think we are in a good spot to start looking at future state impacts.

For example, BCOL Admin is one group that will be impacted with BTR, but then we need to sort our the support process for SI filings in general; this includes:

• Maximus (there was talk about them potentially supporting CORPS, so then would they support SI as well?)
• BCOL Help Desk
• SBC regional offices.
• BC Reg staff

It's on my agenda for our OCM check in tomorrow to start that convo with you, along with some other items.

[Apt766525]

Reviewed the process flows and forms and have shared the files with BCOL admin. Awaiting for feedback.

[Apt766525]

Followed up with BCOL admin for feedback on the process flows. Awaiting response.

[Apt766525]

@mstanton1 Received a response from BCOL admin. Based on initial feedback, the process flow and form for the Beneficial Owner Search looks good and clear as it closely matches the flow for Director Search.

[mstanton1]

@daniwilliamson BTR will require a form for access to competent authority search. BTR is targeted to launch in early 2025 and the search would launch a minimum of 90 days after. Is the preference for us to hold these tickets, or should we pass it to you so it can be worked on when there is capacity?

I don't anticipate large changes, but it's possible there would be some small changes needed when final reviews are taking place.

[daniwilliamson]

@daniwilliamson BTR will require a form for access to competent authority search. BTR is targeted to launch in early 2025 and the search would launch a minimum of 90 days after. Is the preference for us to hold these tickets, or should we pass it to you so it can be worked on when there is capacity?

I don't anticipate large changes, but it's possible there would be some small changes needed when final reviews are taking place.

Hi @mstanton1 - thanks, a heads-up is good, but your team can hang on to these tickets until the form content is finalized. This workflow may also help. To make the process faster/easier for your team, if you give Digital Delivery and the PDF designer access to DEV we can build the PDF form or make revisions to the existing form based on the finalized digital form in DEV. It takes the designer 2-3 days to produce the PDF, so it's a quick turnaround. Let us know if you have questions. FYI @JudyWolstenholme

[mstanton1]

Thanks @daniwilliamson for the information. We will keep this on hold until closer to our release when all is finalized.

[mstanton1]

@Apt766525 in reviewing #17415 I've realized that I don't think this form went through policy for review. Can you confirm if this was provided to policy? If not, can you please pull this back in progress and provide to them with a request to review when time permits?

[Apt766525]

Shared the form with policy for review. Awaiting feedback.

[Apt766525]

Working on updating the form according to feedback and suggestions from Policy.

[Apt766525]

@mstanton1 Updated the request access form and reviewed the wording. Policy has reviewed and confirmed the request access form. https://drive.google.com/file/d/17NFoLNI_oRKOrhwr2EKmkhWLTePBPqW0/view?usp=drive_link

[mstanton1]

Great work. Thanks for getting that reviewed! I'm going to put an "On Hold" label and move it back to the product backlog until we are closer to releasing based upon feedback from Digital Delivery. At that time we can move it forward to have the form created:)

[Apt766525]

@mstanton1 Thanks. Sounds good.

[mstanton1]

@Apt766525 BCOL Admin will not be able to create the account for Competent Authorities. Let's revisit section B in the instructions to advise that if a client does not have an account they will need to create one (and provide the link to the BCROS system).

[mstanton1]

Confirmed that above Item B it notes if approved all clients will need to create a Premium BC Registries account. They are not required to do so in advance as they may not even be approved for competent authority access and account set up is a large task. No further changes needed.