openownership / lib-cove-bods

Check that your data complies with the Beneficial Ownership Data Standard (BODS) using our install our data review library to analyse files via your command line interface
https://datareview.openownership.org/
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Interests with beneficialOwnershipOrControl: true should have a natural person as the interested party #47

Closed siwhitehouse closed 3 years ago

siwhitehouse commented 4 years ago

Given an ownership-or-control-statement where

"statementType": "ownershipOrControlStatement",

and

"interests": [
      {
        ...
        ...
        "beneficialOwnershipOrControl":true,
        ...
        }
      }
    ],

then

 "interestedParty": {
      "describedByPersonStatement": "person-statement-identifier"
    },

must be present.

odscjames commented 4 years ago

Is it possible interestedParty/unspecified might be set instead?

siwhitehouse commented 4 years ago

I think it can, yes. BODS requires that beneficial ownership is a property of a natural person, but allows for that person to be unspecified.

So, I think we can add

or

 "interestedParty": {
      "describedByPersonStatement": "person-statement-identifier"
    },

to the description above.

@ScatteredInk for confirmation.

ScatteredInk commented 4 years ago

From the unspecified description:

When confirmation has been provided that no interested party exists, where ownership and control information does not need to be provided, or where details of ownership and control are unknown, a reason MUST be given. Where an unknown entity is the subject of further ownershipOrControlStatements in the same structure, or where there is a natural person with ownership or control but their name or details are not known or cannot be disclosed for some reason, unspecified should not be used, but instead a reference to a personStatement or entityStatement should be provided but identifying details MAY be left blank.

I think this therefore means that whenever we are able to use beneficialOwnershipOrControl: True, there must be a personStatement as the interestedParty - so the original test is correct. The description of unspecified is very long and confusing - I think this test can help us clarify it.

odscjames commented 3 years ago

Call with @kd-ods

Applies to 0.1 & 0.2 schema version.

Having looked at this, @siwhitehouse has added an or clause but actually that is not needed. If the person is unspecified then there should still be an unknown person statement for them so in the ownershipOrControlStatement there will still be a personId.

odscjames commented 3 years ago

This is now in the library - just need to do a release of the library, go to cove, update deps and add the UI text for the new type to https://github.com/openownership/cove-bods/blob/master/cove_bods/templates/cove_bods/additional_checks_table.html

odscjames commented 3 years ago

Live