Requirements: Rules for Minors

[mstanton1]

Identify rules when a minor is a significant individual in a company:

1. Is all data still collected for the minor? All data is still collected for the minor. A minor may or may not have a SIN, but all the typical SI information fields would be expected to be filled in ((including a description of why a SIN was not provided, if a minor does not have one yet). 2. Is data hidden in public search? If so, what data is hidden? Is there any requirements to specify a record exists but cannot be displayed? The registrar must omit from or obscure in publicly accessible information any information about a SI if the information filed with the registrar indicates the individual is under 19 years of age. This means all information about a minor SI, including their name, cannot be available to the public. The Registrar must omit / obscure this information. If the public searches the RTR by company name or incorporation number, the Registrar could choose to obscure the minor SI information in the search result by redacting the information, this could make it clearer to the public that the company has filed some SI information, but that it is not publicly accessible. In addition, an information banner could be provided on the RTR public search application indicating some SI information has been obscured under section 399.52(1) of the Business Corporations Act. 3. Is data hidden in competent authority search? If so, what data is hidden? Is there any requirements to specify a record exists but cannot be displayed? This data would not be hidden in competent authority search. Competent authorities can see all the filed information of a minor SI. 4. During collection of data for a minor do we need to provide any information about hiding / showing that data? When a company is inputting SI information on a TR filing, there is no provision in the legislation requiring the Registrar to provide any information about hiding/showing that data. However, it might be good practice for educational purposes to show an information note in the filing that all the SI’s information will be obscured from publicly accessible information while under age 19. 5. If minor data is hidden, at what point does it become visible? The registrar may cease omitting or obscuring information about an underage SI 90 days after the date that the registrar receives satisfactory records, information or proof verifying, as applicable, that the individual has reached 19 years of age. Since in our modernized system we have the DOB of the SI, this information can be used to determine the date the SI turns 19. The Registrar should continue to obscure the SI information for an additional 90 days after the SI’s 19th birthday. This additional 90 days gives the SI some time to apply to obscure their information if they feel there is threat to their safety if some of their information becomes publicly accessible. 6. Others? The Registrar will need to make sure that a member of public cannot search the RTR by a minor’s name. If a company adds an SI to the RTR and does not provide the SI’s birthdate (i.e., they leave the birthdate field blank), the Registrar should not assume they are a minor. The filed SI information needs to indicate the individual is under 19 years of age for the Registrar to omit or obscure the SI information from the publicly accessible information due to being under age.

[mstanton1]

@Apt766525 can you target having the rules for this (or a first draft) by the end of next week? While this isn't scheduled until late into next PI having some key details will be important for our t-shirt sizing so we can have confidence in what we've committed to next PI.

[Apt766525]

@mstanton1 Have updated the requirements for handling minor information in the description.

[mstanton1]

@forgeuxGH5 @J-Baese requirements for display of minors are above. This is currently slated for after change, but overlaps a bit with obscure. My assumption is that @J-Baese might have capacity first. Let's chat about who will work on this and coordinate a review with @Apt766525 before this is moved to closed.