Open stevenday opened 5 years ago
A related but more specific, question. How would you map something like PSC's super secure exemption? Reading the ownershipOrControlStatement guidance, I went for interested-party-exempt-from-disclosure
. However, looking a personStatement, I could just as easily map them as a anonymousPerson
(which I've now switched to).
If we recommend something like this super-secure system in our wider guidance (I think we do in the privacy report) it seems worth having an explicit mention of when exemption
differs from anonymity in the BODS guidance?
Thanks @stevenday. Yes - this is not very clear at the moment as missing info can appear in multiple places (in a person, entity or ownership-or-control statement but draws from a single codelist).
I think it makes sense to split that codelist into separate ones but that brings its own complications and I couldn't work out how to do it without a big overhaul to the documentation, which we didn't have time for before the 0.2 release. There will be a bigger pool of example data to draw on when I merge in the Ukraine ones, so hopefully that will help with the ambiguous documentation around this in the short term.
Would just
subject-unable-to-identify-beneficial-owner
be clearer?
That's a good idea - will make that change in 0.3.
For a super secure person, I would model as an anonymousPerson with:
"unspecifiedPersonDetails": {
"reason": "interested-party-exempt-from-disclosure",
"description": "set phrase from companies house enumerations describing SSP status"
}
Updated title to reflect the task of aligning codelists and docs with the structure of the standard.
Just noting here that 'subject-exempt-from-disclosure' should be re-worded to sthg like 'subject-exempt-from-disclosing-beneficial-owners' for clarity. This brings the code in line with its described meaning. Otherwise it can be interpreted to mean that the subject is exempt from disclosing its own identity (esp since the equivalent exists at the other end of the relation as interested-party-exempt-from-disclosure).
In #96, we changed the codelist for the
reason
field inunspecified
ownershipOrControlStatement
s to include more reasons. It went from:unknown
,noBeneficialOwners
noNotifiableOwners
to:
no-beneficial-owners
subject-unable-to-confirm-or-identify-beneficial-owner
interested-party-has-not-provided-information
subject-exempt-from-disclosure
interested-party-exempt-from-disclosure
unknown
However, we also have guidance that states:
To me, that seems to make
interested-party-has-not-provided-information
,subject-exempt-from-disclosure
andinterested-party-exempt-from-disclosure
completely defunct? They all indicate there is a person, so there should be anunknownPerson
personStatement?It also potentially contradicts with the
confirm
part ofsubject-unable-to-confirm-or-identify-beneficial-owner
. In the PSC register, reasons like this mean that someone has been identified, but the details haven't been confirmed. e.g. forpsc-details-not-confirmed
Would just
subject-unable-to-identify-beneficial-owner
be clearer?I've been trying to update the register's export process, in particular matching up PSC's reasons to this and found it quite confusing. Are there other cases I'm missing where they're necessary?